Joon Lee v. Mercedes-Benz USA LLC

Summary

The court denied Plaintiff Joon Lee’s motion to remand an action against Mercedes-Benz USA LLC under the California Song-Beverly Consumer Warranty Act. It held that diversity jurisdiction existed because the amount in controversy exceeded $75,000 when Plaintiff’s alleged actual damages and a potentially available civil penalty of twice those damages were included.

Holdings

1. A civil penalty sought under the Song-Beverly Consumer Warranty Act may be included in determining the amount in controversy when the complaint places the penalty at issue and alleges facts supporting its availability.
2. The amount-in-controversy requirement for diversity jurisdiction was satisfied because the alleged actual damages of $50,383.02, together with a potential civil penalty of $100,766.04, produced an amount in controversy of $151,149.06, exceeding $75,000.

Questions Presented

1. Whether the amount in controversy exceeded $75,000 for purposes of diversity jurisdiction under 28 U.S.C. § 1332.
2. Whether the Song-Beverly Act civil penalty sought in the complaint should be included in calculating the amount in controversy.

Disposition

remanded