Ware v. Best Buy Stores, L.P.

Dist. Ct. lacked subject-matter jurisdiction to consider plaintiffs’ class action claim, alleging that defendant retailer violated Magnuson-Moss Warranty Act by giving customers who purchased extended warranty plan gift card as sole remedy, where defendant could not repair television purchased from defendant, and where said Act required that consumer be given choice between replacement of television or refund of purchase price less depreciation based on actual use. Dist. Ct. lacked federal-question jurisdiction under 28 USC section 1331, since: (1) Magnuson-Moss Act required that plaintiffs show amount-in-controversy of at least $50,000 in alleged damages and plaintiffs had only $5,000 in damages; and (2) plaintiffs failed to name any additional plaintiffs for purposes of aggregating their claims to meet amount-in-controversy threshold. Also, plaintiffs failed to plausibly allege amount-in-controversy that would satisfy Class Action Fairness Act jurisdiction requirement, where plaintiffs failed to make any factual allegations that class action contained at least $5 million in claims. Too, plaintiffs could not establish any diversity jurisdiction under 28 USC section 1332, where plaintiffs’ issues with its $3,000 television could not establish more than $75,000 in controversy between them and manufacturer of television.