People of the State of California v. General Motors LLC
| The People of the State of California |
| General Motors L.L.C. |
| 1:2014cv07787 |
| September 25, 2014 |
| US District Court for the Southern District of New York |
| Foley Square Office |
| XX Out of State |
| Jesse M. Furman |
| Other Statutory Actions |
| 28 U.S.C. ยง 1441 |
| Plaintiff |
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Filing
64
OPINION AND ORDER re: (43 in 1:14-cv-07787-JMF) MOTION to Remand to State Court Notice of Motion and Motion to Remand by Plaintiff The People of the State of California filed by The People of the State of California, (335 in 1:14-m d-02543-JMF) MOTION to Remand to State Court (This document relates to The People of the State of California v. General Motors LLC, Case No. 1:14-cv-07787) filed by The People of the State of California: For the foregoing reasons, the Court concludes that subject-matter jurisdiction is lacking with respect to this case and that the case must be remanded to the Orange County Superior Court from which it was removed. The Court recognizes that that conclusion comes with a cos t. As this Court has observed, "[p]utting aside the natural temptation to find federal jurisdiction every time a [high] dollar case with national implications arrives at the doorstep of a federal court, the federal courts undoubtedly have a dvantages over their state counterparts when it comes to managing a set of substantial cases filed in jurisdictions throughout the country." Standard & Poor's, 2014 WL 2481906, at *27 (internal quotation marks and brackets omitted). The present MDL illustrates many of those advantages, as the Court has been able to manage and oversee the claims of well over a thousand plaintiffs in a manner that promotes efficiency and minimizes the risks of inconsistent rulings and unnecessary d uplication of efforts. Nevertheless, as the Court has made clear, it also has tools to promote coordination with related cases pending in state court, whether through communication with judges presiding over those cases or, where counsel in those cases is among the leadership in the MDL (as in this case), through counsel. (See 14-MD-2543, Order No. 15 (Docket No. 315) (establishing procedures for coordinated discovery in this MDL and related state court proceedings). "[I]n any event, as any student of the Constitution knows, efficiency is not the only interest served by this country's federalist system of state and federal courts." Standard & Poor's, 2014 WL 2481906, at *27. In the final analysis, this Court is not free to disregard or evade "[t]he limits upon federal jurisdiction, whether imposed by the Constitution or by Congress." Owen Equip. & Erection Co. v. Kroger, 437 U.S. 365, 374 (1978). For the reasons stated above, the Court conclud es that this case exceeds the limits of federal jurisdiction imposed by Congress. Accordingly, Plaintiff's motion is GRANTED, and the case is remanded back to the Orange County Superior Court. The Clerk of Court is directed to terminate 14-M D-2543 Docket No. 335 and 14-CV-7787 Docket No. 43, to remand 14-CV-7787 back to the Orange County Superior Court, and to then close 14-CV-7787. (Signed by Judge Jesse M. Furman on 11/24/2014) Filed In Associated Cases: 1:14-md-02543-JMF, 1:14-cv-07787-JMF (tn)
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