The Magnuson-Moss Warranty Act (MMWA), 15 U.S.C.S. § 2301 et seq., provides for federal jurisdiction over certain claims. 15 U.S.C.S. § 2310(d)(1)(B). This jurisdiction, however, is subject to an amount-in-controversy requirement. 15 U.S.C.S. § 2310(d)(3)(B) of the MMWA provides that no claim shall be cognizable in a suit brought under § 2310(d)(1)(B) if the amount in controversy is less than the sum or value of $ 50,000 (exclusive of interests and costs) computed on the basis of all claims to be determined in the suit.
Plaintiff recreational vehicle purchaser sought review of a summary judgment from the district court granted in favor of defendant RV manufacturer in plaintiff's action alleging breach of express warranty and claims under the Michigan Consumer Protection Act and the Magnuson Moss Warranty Act. The court raised the issue of jurisdiction and plaintiff, who had filed his complaint in state court, argued that the requisite amount-in-controversy under 15 U.S.C.S. Section 2310(d)(3)(B) could not be met. The court considered plaintiff's state law claims in computing whether the amount-in-controversy requirement was met.
Did the district court have authority to exercise jurisdiction over plaintiff's breach of express warranty matter?
The court determined that the dispute involved $51,451-the amount of plaintiff's contract without offset. Therefore, the court held that it was proper for the district court to exercise jurisdiction. On the merits, the court found harmless error in the district court's reliance on an expert report prepared by defendant's employee, which was not in the form of an affidavit or sworn statement and which concluded that the defects in plaintiff's RV were insubstantial. The court found that the district court's opinion throughly and accurately set forth the undisputed facts and the governing law.
The court affirmed the grant of summary judgment on the basis of the district court's well-reasoned opinion.