Christopher Lloyd Mitchel v. Ford Motor Company et al.

Summary

The United States District Court for the Central District of California grants Plaintiff Christopher Lloyd Mitchel’s motion to remand a Song-Beverly Consumer Warranty Act action against Ford Motor Company. The court concludes that Ford failed to show by a preponderance of the evidence that the amount in controversy exceeded $75,000, and therefore finds no diversity jurisdiction. The case is remanded to the Superior Court of Riverside County, California.

Holdings

1. Ford failed to prove by a preponderance of the evidence that the amount in controversy exceeded $75,000, so the district court lacked diversity jurisdiction.
2. The court declined to include speculative civil penalties or attorney's fees in determining whether the amount in controversy exceeded $75,000.

Questions Presented

1. Whether the district court had diversity subject matter jurisdiction when the complaint did not allege more than $75,000 in damages and Ford's supported economic-damages calculation was $63,636.42.
2. Whether speculative civil penalties and attorney's fees could be included to satisfy the amount-in-controversy requirement.

Disposition

remanded