Case Explained: AMEZCUA V. NISSAN NORTH AMERICA, INC.

Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-07-10

Docket: 5:25-cv-00860-DOC-DTB

The Ninth Circuit vacated the district court’s sua sponte order remanding the case to state court, holding that the district court erred in concluding Nissan failed to meet the $75,000 amount-in-controversy requirement for federal diversity jurisdiction. The court applied the standard from *Dart Cherokee Basin Operating Co. v. Owens*, which requires only a plausible allegation by the defendant that the threshold is met, and mandates that if the court questions this amount, it must provide the defendant a fair opportunity to submit evidence proving the requirement by a preponderance of the evidence. The appellate court reasoned that the district court improperly excluded civil penalties and attorneys’ fees from its calculation; under Ninth Circuit precedent, the amount in controversy encompasses all relief potentially available, including damages, civil penalties, and fee-shifting awards. Because Nissan’s notice of removal plausibly alleged that actual damages combined with potential civil penalties (up to double the damages) and estimated attorneys’ fees exceeded $75,000, and because the district court failed to allow Nissan to prove this before remanding, the remand order was erroneous. The case is remanded for further proceedings consistent with this opinion.

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