Armen Mardusian v. Mercedes-Benz USA, LLC

Summary

The United States District Court for the Central District of California denied Armen Mardusian’s motion to remand a Song-Beverly Consumer Warranty Act action. The court held that complete diversity existed and that the amount in controversy exceeded $75,000 based on the vehicle’s purchase price and potential civil penalties.

Holdings

1. Complete diversity existed because Plaintiff was adequately shown to be a California citizen, while Mercedes-Benz USA, LLC, whose sole member was incorporated in Delaware and had its principal place of business in Michigan, was a citizen of Delaware and Michigan rather than California.
2. The amount in controversy exceeded $75,000 because the $70,080.24 purchase price, together with potential civil penalties of up to twice the actual damages, yielded a potential recovery of $210,240.72.

Questions Presented

1. Whether the parties were completely diverse for purposes of federal diversity jurisdiction.
2. Whether the amount in controversy exceeded $75,000, including potential civil penalties under the Song-Beverly Act.
3. Whether the removed action should be remanded to state court for lack of subject matter jurisdiction.

Disposition

remanded