Federal Court Retains Jurisdiction in Single-Car Rollover Accident Case -Small v. Ford Motor Company

In Small v. Ford Motor Company, the U.S. District Court for the Southern District of Florida explains that a plaintiff in a Florida car accident case can’t add defendants after suing simply for the purpose of defeating a federal court’s jurisdiction.

The suit was brought on behalf of Ms. Small, who was injured in a rollover car accident on June 20, 2011 when she was ejected from a Ford Explorer in which she had been riding as a passenger. She sued Ford Motor Company, the car’s manufacturer, and seatbelt maker Breed Technologies in state court, claiming that she was injured due to deficiencies in the car’s restraint system, suspension and interior components as well as the rear panel and glass. The Defendants later removed the case to federal court in the Southern District on diversity grounds: the parties are residents of different states.

In a bit of legal wrangling, the Plaintiff later sought to amend her complaint to add South Florida Auto Auction of Fort Lauderdale – the dealership that sold the used car to the owner, who was driving at the time of accident – as a defendant. She also argued that the action should be remanded to state court because the addition of SFAAFL destroyed the complete diversity necessary for federal jurisdiction in this case. In order for a federal court to exercise jurisdiction based on diversity, each party must be from a different state than the other. Ford and Breed opposed the motion to amend, claiming it was meritless and intended solely to force the court to send the case back to state court.

The Southern District sided with the Defendants, denying the motions to amend and remand. “In deciding whether to permit or deny joinder, the district court must balance the defendant’s interests in maintaining the federal forum with the competing interests of not having parallel lawsuits,” the court explained.

In this case, the court said that the timing of the motion to amend – immediately after the matter was removed from state to federal court – strongly suggested that it was meant only to destroy federal jurisdiction. Although Plaintiff claimed that she had had trouble locating the car’s seller, the court noted that she did not seek to add SFAAFL until more than a year after the accident happened.

The court further explained that Plaintiff will not be harmed if the dealer is not added as a defendant because she can obtain a complete judgment against Ford and Breed without SFAAFL involved as a party. “Plaintiff has at least one fully solvent defendant (Ford Motor Company) who will be able to satisfy any judgment obtained in this case,” the court said.

Jurisdiction and the identification of potential defendants are just two of the many issues a person seeking to sue for injuries incurred in a car accident must consider before filing an action. An experienced personal injury attorney is vital to pursuing an accident claim, not to mention determining whom to pursue it against. The South Florida car accident lawyers at Anidjar & Levine represent clients throughout the area, including in Coral Springs, Hialeah and Pompano Beach, and offer a free initial consultation from our Fort Lauderdale offices. Call the firm today at 800-747-3733.

Related blog posts:

Florida Court Says Automaker May be Liable for Single-Car Accident – Rooker v. Ford Motor Company

Comparative Negligence Evidence in Florida Car Accident Cases – Lenhart v. Basora

Court Finds Cement Truck Driver Liable in Florida Rear End Accident – Douglas-Seibert v. Riccucci