Ryan Frankin v. FCA US LLC

I. BACKGROUND

On January 14, 2020, Plaintiff commenced this action in Riverside County Superior Court. (Notice of Removal (“NoR”) ¶ 1 (Docket No. 1); Complaint (Docket No. 1-1)). The Complaint contains the following allegations: On or about July 1, 2018, Plaintiff leased a 2019 Ram 1500 (“Vehicle”), which was manufactured and/or distributed by FCA. (Complaint ¶¶ 4-5). In connection with the purchase, Plaintiff received an express written warranty in which FCA stated that the Vehicle and its components would be free from all defects in material and workmanship, that the Vehicle would pass without objection in the trade under the contract description, that the Vehicle would be fit for the ordinary purpose for which it was intended, that the Vehicle would conform to the promises and affirmations of fact made, and that FCA would perform any repairs to ensure the Vehicle was free from defects for the time period specified under the warranty. (Id. ¶ 7). Plaintiff has performed, but has been forced to deliver the Vehicle to FCA’s authorized service and repair facilities on at least four occasions. (Id. ¶¶ 8-9). By way of example, the defects, malfunctions, mis-adjustments, and…