Teshaun Deberry v. Mercedes-Benz USA, LLC et al.

Summary

The United States District Court for the Central District of California granted Plaintiff Teshaun Deberry’s motion to remand a vehicle warranty action to the Superior Court of California, County of Riverside. The court held that Mercedes-Benz USA, LLC’s removal based on the Magnuson-Moss Warranty Act claim was untimely because the thirty-day removal period began when Defendant received the First Amended Complaint on February 4, 2025. The court concluded that the Magnuson-Moss Act’s $50,000 amount-in-controversy requirement was satisfied, but remanded the case based on the procedural defect.

Holdings

1. When a defendant has been served with the initial summons and subsequently receives an amended complaint that first establishes removability, the thirty-day removal period under 28 U.S.C. § 1446(b)(3) begins upon receipt of the amended complaint. Defendant's removal on March 26, 2025, more than thirty days after receipt of the February 4, 2025 first amended complaint, was untimely.
2. The Magnuson-Moss Warranty Act's minimum amount-in-controversy requirement was satisfied because the vehicle's total contract price was $65,733.52, exceeding the statutory minimum of $50,000.

Questions Presented

1. Whether Defendant's March 26, 2025 notice of removal was timely when Plaintiff's first amended complaint adding a federal Magnuson-Moss claim was filed and received on February 4, 2025, after Defendant had already been served with the initial summons.
2. Whether the Magnuson-Moss Warranty Act's minimum amount-in-controversy requirement of $50,000 was satisfied.

Disposition

remanded