Guijarro v. Enterprise Holdings, Inc., No. 21-40512 (5th Cir. 2022)
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Joanna Guijarro rented a Jeep from Enterprise Rent-A-Car in Brownsville Texas, which is owned and operated by EAN, a Delaware LLC, whose sole member is a Missouri corporation, Enterprise Holdings. The Guijarros were driving in heavy rain when Joanna lost control of the Jeep. The vehicle slammed into a concrete culvert. All three family members were injured. The Guijarros believed that a defect in the Jeep’s braking system caused the accident. They sued Enterprise Holdings and EAN in Texas state court, alleging negligence, breach of contract, and violations of the Deceptive Trade Practices Act, claiming that the defendants knew or should have known that the Jeep’s brakes “were in a defective and/or unsafe condition” and failed to disclose or correct the problem. The defendants removed the suit to federal court.
The Fifth Circuit affirmed the denial of the plaintiffs' remand motions, finding it apparent from the complaint that the amount in controversy exceeded $75,000 and that the Guijarros only sought to join Texas parties to escape federal court. Enterprise Holdings was properly dismissed as a defendant. Summary judgment for EAN was appropriate because Guijarro failed to produce competent evidence that the Jeep’s brakes were defective. Texas law required expert opinions that identified a “specific defect” in the vehicle and “ruled out other possible causes” for the crash. The only proof of a defect was Joanna’s lay testimony “that she applied the brakes” and the car “would not stop.”
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