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Chisum v. Mercedes-Benz USA, LLC

United States District Court, M.D. Louisiana

April 15, 2019

GAIL CHISUM
v.
MERCEDES-BENZ USA, LLC ET AL.

          RULING AND ORDER

          Brian A. Jackson, United States District Judge.

         Before the Court is Defendant Mercedes-Benz USA, LLC's Motion to Dismiss (Doc. 12) Plaintiff Gail Chisum's claims for lack of subject-matter jurisdiction. For the reasons that follow, the Motion (Doc. 12) is DENIED.

         I. BACKGROUND

         This breach-of-warranty case arises from Gail Chisum's purchase of a motorhome that he contends is defective. (Docs. 22).

         Chisum sued Mercedes-Benz, alleging claims under the Louisiana Civil Code's redhibition articles and the Magnuson-Moss Warranty Act. (Doc. 1). In his original complaint, he alleges that he bought a $102, 000 Mercedes-Benz motorhome and that the motorhome is defective. (Id.). He alleges that the Court has subject-matter jurisdiction under the Magnuson-Moss Warranty Act. (Id. at ¶ 3).

         Mercedes-Benz moves to dismiss Chisum's suit for lack of subject-matter jurisdiction. (Doc. 12). It argues that the Magnuson-Moss Warranty Act's amount in controversy requirement is not met because the only item on the motorhome that it warranted is a chassis with an MSRP of $39, 055. (Doc. 12-1 at p. 2). It reasons that, because its breach-of-warranty liability cannot exceed the value of the item it warranted, it is "legally certain" that Chisum cannot satisfy the amount in controversy requirement. (Id. at p. 4). Chisum disagrees. (Doc. 17).

         Chisum argues that his good-faith demand of more than $100, 000 controls. (Id. at p. 4). He offers summary judgment-type evidence, including an affidavit, to support his assertion that at least $50, 000 is in controversy. (Doc. 17-1). And he correctly notes that the amount in controversy under the Magnuson-Moss Warranty Act is "computed on the basis of all claims to be determined in [the] suit," not just his claims against Mercedes-Benz. See 15 U.S.C. § 2310(d)(3)(B) (emphasis added).

         To clarify the amount in controversy, Chisum amended his complaint to name two more defendants: Winnebago Industries and Miller's RV Center. (Doc. 22). In his amended complaint, he alleges that he bought a $102, 000 Winnebago motorhome from Miller's RV Center and that the motorhome is defective. (Id. at ¶ 13). He seeks to rescind the sale and recover the purchase price. (Id. at ¶ 29). He again alleges that the Court has subject-matter jurisdiction under the Magnuson-Moss Warranty Act. (Id. at ¶ 5).

         II. LEGAL STANDARD

         This Courtis a court of limited jurisdiction. See Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994). Because Chisum invokes the Court's jurisdiction, he bears the burden of proving it. See United States ex rel. Jamison v. McKesson Corp., 649 F.3d 322, 327 (5th Cir. 2017).

         III. DISCUSSION

         A. The Magnuson-Moss Warranty Act

         The Magnuson-Moss Warranty Act grants federal courts jurisdiction over claims for breach of warranty when the amount in controversy is at least $50, 000. See 15 U.S.C. § 2310(d)(3)(B). To determine the amount in controversy under the Act, the Court looks to the measure of damages under state law. See Scarlott v. Nissan North Am., Inc., 771 F.3d 883, 887 (5th Cir. 2014). Louisiana law supplies that measure.

         B. Damages for ...


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