Coker v. Daimlerchrysler Corp.

Decision Date05 September 2002
Docket NumberNo. Civ.A. 102CV903-RWS.,Civ.A. 102CV903-RWS.
Citation220 F.Supp.2d 1367
PartiesBeatrice COKER and Jimmy L. Colbert, individually and on behalf of all others similarly situated, Plaintiffs, v. DAIMLERCHRYSLER CORPORATION and Chrysler Corporation, Defendants.
CourtU.S. District Court — Northern District of Georgia

Lance Alan Cooper, Scott B. Cooper, Andrew W. Jones, Cooper & Jones, Marietta, GA, for Plaintiffs.

Charles A. Newman, John W. Rogers, Kathy Wisniewski, Bryan Cave, St. Louis, MO, Mary Diane Owens, Anandhi S. Rajan, Swift, Currie, McGhee & Hiers, Atlanta, GA, for Defendants.

ORDER

STORY, District Judge.

This case is before the Court on Plaintiffs' Motion to Remand [7-1], Plaintiffs' Motion for Rule 11 Sanctions [12-1], and Defendant's Motion to File a Supplemental Memorandum of Law in Support of Opposition to Plaintiff's Motion to Remand [24-1]. Also pending are Defendant's Motion to Dismiss [2-1] and Defendant's Motion to File Memorandum of Law in Excess of 25 Pages [3-1], further action on which has been postponed by Consent Order [6-1] until the Court's Order on Plaintiffs' Motion to Remand. As a preliminary matter, Defendant's Motion to File a Supplemental Memorandum [24-1] is GRANTED. After reviewing all of the record and the arguments of the parties, the Court enters the following ORDER.

Factual Background

Plaintiffs Beatrice Coker and Jimmy L. Colbert originally brought this action in the Superior Court of Fulton County, Georgia, against Defendant DaimlerChrysler Corporation. In their Complaint, Plaintiffs bring claims individually and on behalf of a putative class, defined as follows:

All residents of Georgia who own or lease model year 1993-2002 vehicles manufactured and/or sold by Chrysler equipped with Gen-3 seat belt buckles; and all non-residents of Georgia who own or lease model year 1993-2002 Chrysler vehicles equipped with Gen-3 seat belt buckles, which were purchased or leased in Georgia by such non-residents.

(Pl.Compl.¶ 25.) According to Plaintiffs, the Gen-3 seat belt buckles are defective because they are subject to accidental release, especially in the event of a collision. Plaintiffs allege that the buckles fail to comply with applicable safety standards, including those set forth by the National Highway Transportation Safety Administration ("NHTSA"). All of Plaintiffs' counts, which include breach of express warranty, breach of implied warranty of merchantability, breach of implied warranty of fitness for a particular purpose, negligence, and negligent misrepresentation, are made pursuant to state law. Plaintiffs seek damages associated with replacing the Gen-3 Buckles.

On April 8, 2002, Defendant removed this case to federal court, asserting federal question jurisdiction pursuant to 28 U.S.C. § 1441. Thereafter, Plaintiffs moved to remand this case and requested attorney's fees pursuant to 28 U.S.C. § 1447(c). Additionally, Plaintiffs moved for sanctions pursuant to Fed.R.Civ.P. 11.

This case is one of several that have been filed against Defendant in state courts alleging defective seat belts. See Sylvester v. DaimlerChrysler Corp., No. 1:02CV0567 (N.D.Ohio May 30, 2002) (remanding similar case); Inman v. DaimlerChrysler Corp., No. C-00-340 (S.D.Tex. Dec. 7, 2000) (same); Hiller v. DaimlerChrysler Corp., No. 1:02-10533 (D.Mass. filed Feb. 15, 2002) (similar case). After removing Hiller, Sylvester, and this case to federal district courts, Defendant moved to transfer the cases for consolidated proceedings before the Judicial Panel on Multidistrict Litigation. The Judicial Panel entered an order denying transfer on August 12, 2002. In re DaimlerChrysler Corp. Seat Belt Buckle Prod. Liab. Litig., 217 F.Supp.2d 1376 (Jud.Pan. Mult.Lit.2002).

Discussion
I. Federal Jurisdiction

Unless Congress explicitly provides otherwise, a defendant may remove to federal court a civil action brought in state court, provided that the federal court has original jurisdiction over the action. 28 U.S.C. § 1441(a)-(b). Original jurisdiction may be based on a federal question or on diversity of citizenship. Id. §§ 1331-1332. Here, diversity jurisdiction is lacking; thus, removal jurisdiction must be based on the presence of a federal question.1

Defendant relies for removal on 28 U.S.C. § 1331, which establishes "original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States." Removal jurisdiction is governed by the well-pleaded complaint rule, which "provides that federal jurisdiction exists only when a federal question is presented on the face of the plaintiff's properly pleaded complaint." Caterpillar, Inc. v. Williams, 482 U.S. 386, 392, 107 S.Ct. 2425, 2429, 96 L.Ed.2d 318 (1987). Moreover, removal jurisdiction is construed narrowly, and any doubts about jurisdiction are resolved in favor of the non-removing party. Diaz v. Sheppard, 85 F.3d 1502, 1505 (11th Cir.1996).

Generally, "a case arises under federal law only if it is federal law that creates the cause of action." Id.; see Franchise Tax Bd. v. Constr. Laborers Vacation Trust for S. Cal., 463 U.S. 1, 8-10, 103 S.Ct. 2841, 2845-47, 77 L.Ed.2d 420 (1983) (setting forth principles). Indeed, in Merrell Dow Pharmaceuticals, Inc. v. Thompson, the Supreme Court held that where Congress had determined that there should be no private federal cause of action under a federal statute, a complaint alleging violation of that statute as an element of a state cause of action failed to create federal question jurisdiction. 478 U.S. 804, 819, 106 S.Ct. 3229, 3237, 92 L.Ed.2d 650 (1986). Even though Merrell Dow recognized that there may be an exceptional case in which federal question jurisdiction is available, 478 U.S. at 808-09, 106 S.Ct. 3229, this principle does not disturb "the long-settled understanding that the mere presence of a federal issue in a state cause of action does not automatically confer federal-question jurisdiction." Id. at 813, 106 S.Ct. 3229.

The Eleventh Circuit has followed these standards, noting that in narrow circumstances "jurisdiction may be available if a substantial, disputed question of federal law is a necessary element of a state cause of action." Jairath v. Dyer, 154 F.3d 1280, 1282 (11th Cir.1998). However, "it will be only the exceptional federal statute that does not provide for a private remedy but still raises a federal question substantial enough to confer federal question jurisdiction when it is an element of a state cause of action." Bellsouth Telecomm. v. MCImetro Access Transmission, 278 F.3d 1223 (11th Cir.2002) (quoting City of Huntsville v. City of Madison, 24 F.3d 169, 174 (11th Cir.1994)) (internal quotations omitted).2

In Jairath v. Dyer, for example, a plaintiff brought suit pursuant to state law for damages based on breach of a duty created by the Americans with Disabilities Act ("ADA"). 154 F.3d at 1280. The defendant removed the case to federal court, but the Eleventh Circuit held that the district court lacked subject matter jurisdiction. Id. at 1280-81. The court reasoned that the plaintiff's claims did not arise under federal law because there was no private cause of action for a damages remedy under the ADA. Id. at 1283. Absent special circumstances, therefore, a state law cause of action that simply incorporates the violation of a federal duty as an element does not make that element so "necessary" as to confer federal jurisdiction. See id. at 1282-83 (discussing principles).

In determining whether a particular case falls within the "necessary element" exception, it is useful to evaluate the nature of the federal interest at stake. Merrell Dow, 478 U.S. at 814 n. 12, 106 S.Ct. 3229. For example, federal jurisdiction may be proper where the validity of a federal statute is challenged; in contrast, where violation of a federal statute merely supports an element of a state claim, federal jurisdiction is generally lacking. Id.Compare In re Wireless Tel. Radio Frequency Emissions Prods. Liab. Litig., 216 F.Supp.2d 474, 488-89 (D.Md.2002) (federal jurisdiction proper where plaintiffs' claims would essentially invalidate federal law), with Diaz v. Sheppard, 85 F.3d 1502 (11th Cir.1996) (remand required where prisoner made state-law claim for legal malpractice, even though attorney's understanding of Eighth Amendment would be at issue in determining malpractice), and Hill v. Marston, 13 F.3d 1548 (11th Cir. 1994) (remand required where complaint alleged violations of state securities statutes, even though elements of state law claim included knowledge of and failure to comply with federal securities regulations).

Similarly, where resolution of a federal issue would determine the outcome of a case, federal jurisdiction may be appropriate; in contrast, where state-law claims do not depend for their success on favorable resolution of the federal issues, they often do not meet the requirements for federal jurisdiction. Compare Ayres v. General Motors Corp., 234 F.3d 514 (11th Cir.2000) (jurisdiction appropriate where resolution of case depended "entirely on interpretation of the federal mail and wire fraud statutes and their interaction with the [Vehicle] Safety Act"), with Sylvester v. DaimlerChrysler Corp., No. 1:02CV0567 (N.D.Ohio May 30, 2002) (remand required where plaintiffs' success did not depend on finding that defendants violated federal regulations).

The above distinctions provide guidance in evaluating the parties' arguments here. Plaintiffs' complaint alleges in part that the Gen-3 Buckle does not comply with NHTSA standards. (Pl.Compl.¶ 8.) In particular, Plaintiffs state that the buckle does not conform to a provision requiring that a "[b]uckle release mechanism shall be designed to minimize the possibility of accidental release." 49 C.F.R. § 571.209 S4.1(e). Defendant argues that Count I of the complaint necessarily requires determination of federal issues because it states that Defendant breached its express warranty that its...

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  • Daimlerchrysler Corp. v. Inman
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    • 1 Febrero 2008
    ...*3, 2004 WL 574331 (D.Mass. Mar.23, 2004). Two other state court class actions have been removed and remanded. Coker v. DaimlerChrysler Corp., 220 F.Supp.2d 1367 (N.D.Ga. 2002); Sylvester v. DaimlerChrysler Corp., No. 1:02CV0567, 2002 U.S. Dist. LEXIS 17989, 2002 WL 32005242 (N.D.Ohio Mar.2......
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    ...a pleading in bad faith for an improper purpose. Id. at 1301 (quotes and cites omitted; emphasis added); Coker v. DaimlerChrysler Corp., 220 F.Supp.2d 1367, 1373 (N.D.Ga. 2002). The rule incorporates an objective standard. Donaldson v. Clark, 819 F.2d 1551, 1556 (11th Cir.1987). Hence, cour......
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    ...per se federal-question jurisdiction: 1. Cases involving challenges to the validity of a federal law. Coker v. DaimlerChrysler Corp., 220 F. Supp. 2d 1367, 1370 (N.D. Ga. Sept. 5, 2002); 2. Those impacting federal-government operations. Grable & Sons Metal Prods., Inc. v. Darue Eng'g & Mfg.......

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