Mayra Aragon v. FCA US, LLC, et al.

Summary

The court remands Mayra Aragon’s Song-Beverly Consumer Warranty Act action against FCA US, LLC to the Los Angeles County Superior Court for lack of subject matter jurisdiction. The court concludes that FCA failed to establish by a preponderance of the evidence that the amount in controversy exceeded $75,000, because civil penalties and attorney’s fees were too speculative or inadequately supported.

Holdings

1. FCA failed to establish by a preponderance of the evidence that the amount in controversy exceeded $75,000, so the district court lacked subject matter jurisdiction and was required to remand the action.
2. Potential civil penalties could not be included in the amount-in-controversy calculation because FCA provided no specific facts or evidence showing that Aragon was reasonably likely to recover them or that the actual damages would reasonably be doubled.
3. Potential attorney's fees could be considered, but FCA failed to prove by a preponderance of the evidence that a reasonable fee award would supply the $22,338.72 needed to exceed the jurisdictional threshold.

Questions Presented

1. Whether FCA established by a preponderance of the evidence that the amount in controversy exceeded $75,000 for purposes of diversity jurisdiction.
2. Whether the asserted actual damages, potential Song-Beverly civil penalties, and attorney's fees were sufficiently supported for inclusion in the amount-in-controversy calculation.
3. Whether the action should be remanded to state court for lack of subject matter jurisdiction.

Disposition

remanded