Case Law Update: Dondeti v. Jaguar Land Rover, Warranty Suit Recommended for Dismissal Over the $50,000 Federal Threshold

A federal magistrate judge in Austin has recommended throwing out a Range Rover owner's warranty lawsuit, not because the vehicle was fine, but because the owner never put a dollar figure on his loss. On September 8, 2026, United States Magistrate Judge Susan Hightower issued a Report and Recommendation in Dondeti v. Jaguar Land Rover North America, LLC, No. 1:26-cv-00680-ADA-SH (W.D. Tex.), recommending dismissal of the case without prejudice for lack of subject matter jurisdiction because the plaintiff failed to prove that at least $50,000 was in controversy under the federal Magnuson-Moss Warranty Act. The recommendation is not final; the district judge reviews it after a 14-day objection window.

What the case is about

Per the complaint, Srikar Reddy Dondeti bought a new 2025 Land Rover Range Rover Velar on June 2, 2025 from Park Place Jaguar Land Rover DFW for about $79,205. He alleges defects affecting "its electrical systems, body components, climate control system, and suspension," that he returned it for repairs four times, that it has been out of service for at least thirty days, and that the defects kept recurring. Those are allegations, not findings; the court never reached whether the vehicle was defective.

Dondeti sued on March 20, 2026 under the Magnuson-Moss Warranty Act, 15 U.S.C. § 2301 and following, adding state-law claims for breach of express warranty, breach of implied warranty of merchantability, and violations of the Texas Deceptive Trade Practices Act. Jaguar moved to dismiss under Rule 12(b)(1), arguing the case could not clear the Act's jurisdictional floor.

The ruling: the $50,000 floor is the plaintiff's burden

Magnuson-Moss lets consumers sue in federal court for breach of warranty, but only when "the amount in controversy is at least $50,000" (quoting Scarlott v. Nissan North America, Inc., 771 F.3d 883, 887 (5th Cir. 2014), citing 15 U.S.C. § 2310(d)(3)). Three categories are carved out of that math. In the magistrate judge's words, "Personal injury damages, attorney's fees, and damages for pendent state law claims may not be used to satisfy the MMWA's jurisdictional requirement."

His complaint alleged only that "the amount of controversy exceeds $50,000" and listed "diminution in value of the Subject Vehicle, loss of use, [and] incidental and consequential damages" with no numbers attached. The court found it was not "facially apparent" that the threshold was met, and that "[b]are allegations of jurisdictional facts are insufficient." When a complaint pleads no specific damage amount, a court may look at summary-judgment-type evidence, but Dondeti offered none.

He argued instead that Jaguar had to prove the amount. The court rejected that, distinguishing Scarlott because there "the defendant invoked federal jurisdiction by removing the case from state court." Here, "Dondeti sued in this Court and is the party invoking the Court's jurisdiction. He, not Jaguar, bears the burden of proof." The conclusion: "Because Dondeti offers no evidence or additional allegations to show that the amount in controversy exceeds the jurisdictional amount, the Court finds that he has not sustained his burden to show that jurisdiction exists."

The court also denied his request for leave to amend, because he filed no proposed amended complaint and identified no additional facts he would plead: "Without a proposed amended complaint, the Court cannot assess whether amendment is warranted." Both the denial and the recommended dismissal are without prejudice, so the claims can be brought again with the right proof.

What this means if you have a vehicle warranty or service contract claim

Dondeti is a Texas federal magistrate's recommendation and does not bind any Florida court. The $50,000 threshold comes from the federal statute itself, so the same floor governs Magnuson-Moss claims filed in Florida's federal district courts. A few takeaways, none a substitute for advice on your own facts:

• Put numbers in the pleading. Saying the loss "exceeds $50,000" is a label. Courts in this line of cases want the components: what the vehicle was worth as warranted, what it is worth defective, and the incidental and consequential losses. In Florida, section 672.714(2), Florida Statutes, sets the breach-of-warranty measure as the difference at the time and place of acceptance between the value of the goods accepted and their value as warranted, absent special circumstances showing proximate damages of a different amount.
• Do not count on fees. In the framework this court applied, attorney's fees are excluded from the Magnuson-Moss jurisdictional calculation, as are personal injury damages and damages belonging only to state-law counts. Courts have not been uniform on the fee point, so check the rule in the circuit where you file.
• Who picks the courthouse carries the burden. A consumer who files in federal court owns the burden of establishing jurisdiction. When a company removes a case out of state court, that burden sits with the company instead.
• Federal court is not the only door. State-court breach-of-warranty claims carry no $50,000 federal floor, and Florida has its own Motor Vehicle Warranty Enforcement Act (Chapter 681, Florida Statutes) with separate requirements and deadlines. A dismissal for lack of jurisdiction is about the forum, not the merits.

The same arithmetic appears in vehicle service contract disputes, where the contract price, the denied repair, and the vehicle's diminished value are often three different numbers. Our overview of what a vehicle service contract is explains how those agreements work, and more rulings are on our Case Law and Industry Insights page. Louis Law Group offers a free case evaluation.

Case details: Dondeti v. Jaguar Land Rover North America, LLC, No. 1:26-cv-00680-ADA-SH (W.D. Tex., Austin Division), filed March 20, 2026 under the Magnuson-Moss Warranty Act. Order and Report and Recommendation of Magistrate Judge Susan Hightower, signed September 8, 2026: dismissal without prejudice for lack of subject matter jurisdiction recommended, leave to amend denied without prejudice. Status current as of September 11, 2026.

This article is for general information and is not legal advice. Allegations in a complaint are not findings of fact, and a Report and Recommendation is subject to objection and de novo review by the district judge.