Kierra Chatrice Adams v. FCA US LLC

I. Introduction

Plaintiff Kierra Chatrice Adams filed this lawsuit in Los Angeles Superior Court on May 27, 2020. Dkt. 1, Ex. A. Adams alleged that her 2014 Jeep Cherokee had myriad defects covered by warranty. Id. ¶¶ 9-11. Adams brought claims against the car’s manufacturer, FCA US, LLC (“FCA”), under California’s Song-Beverly Consumer Warranty Act, Cal. Civ. Code § 1790 et seq., under the federal Magnuson-Moss Warranty Act, 15 U.S.C. § 2301 et seq., and for fraudulent inducement/concealment. Id. ¶¶ 124-83. Adams also brought a negligent repair claim against her dealership, Hunter Dodge Chrysler Jeep (“Hunter”). Id. ¶¶ 179-83. FCA removed the case on July 9, 2020, Dkt. 1, and Plaintiff filed this motion to remand on August 11, 2020, Dkt. 12.

II. Legal Standard

Federal courts are courts of limited jurisdiction and have subject matter jurisdiction only where authorized by the Constitution and Congress. See Kokkonen v. Guardian Life Ins. Co., 511 U.S. 375, 377 (1994). A suit filed in state court may be removed to federal court if the federal court would have had original jurisdiction over the suit. 28 U.S.C. § 1441(a). “The removal statute is strictly construed…