Sparrow v. Mazda American Credit
United States District Court for the Eastern District of California
385 F. Supp. 2d 1063 (2005)
- Written by David Bloom, JD
Facts
Cobrain Sparrow (plaintiff) filed suit against Mazda American Credit (Mazda) (defendant) in California state court claiming that Mazda engaged in abusive debt-collection practices in violation of the Fair Debt Collection Practices Act (FDCPA). Mazda removed the case to federal court because Sparrow’s FDCPA claim was brought under federal law. Mazda asserted counterclaims against Sparrow, under state law, for breach of contract and to recover the outstanding debt allegedly owed by Sparrow. Sparrow motioned to dismiss Mazda’s counterclaims. Sparrow argued that Mazda’s counterclaims were permissive counterclaims and that the federal district court lacked supplemental jurisdiction over them. Mazda opposed the motion, arguing that the counterclaims were compulsory and that supplemental jurisdiction existed over them.
Rule of Law
Issue
Holding and Reasoning (Wanger, J.)
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