## Facts

- Glenn Harnden purchased a 2001 Jayco Eagle recreational vehicle for about $51,451.22 from an independent dealer.
- The RV combined a Ford-manufactured chassis with a Jayco-manufactured “home” portion.
- Harnden reported various defects, including water leaks, and sought warranty repairs.
- He sued in Michigan state court alleging breach of contract, breach of express warranty, violations of the Michigan Consumer Protection Act (MCPA), and breach of written warranty under the Magnuson–Moss Warranty Act (MMWA).
- The case was removed to federal court based on the MMWA claim.
- Jayco moved for summary judgment and submitted an inspection report by Jayco employee Randy Zonker stating the RV was in good condition, with only two minor leaks (one not involving a Jayco component and thus not covered).
- Harnden offered no counter-expert and argued the Zonker report was hearsay and not in admissible form for summary judgment.
- Jayco offered to provide admissible support (e.g., affidavit or deposition), but the district court considered the report as submitted and granted summary judgment for Jayco.

## Issues

1. Whether the federal court had subject-matter jurisdiction under the MMWA’s $50,000 amount-in-controversy requirement, making removal proper.
2. Whether Harnden produced sufficient evidence to create a genuine dispute of material fact on his MMWA, MCPA, and express-warranty claims.
3. Whether any error in considering the Zonker report at summary judgment was harmless under Federal Rule of Civil Procedure 61.

## Decision

- The Sixth Circuit held the MMWA amount-in-controversy requirement was satisfied because the complaint sought relief tied to the RV’s purchase price exceeding $50,000, so removal and federal jurisdiction were proper.
- The court affirmed summary judgment for Jayco because Harnden failed to present significant probative evidence contradicting Jayco’s showing that the alleged defects were minor, repairable, or not covered.
- Assuming arguendo the Zonker report was improperly considered under Rule 56, the court held any error was harmless under Rule 61 because Harnden showed no prejudice and remand would only permit the same evidence to be resubmitted in admissible form with the same result.

## Legal Principles

- Under the MMWA, federal jurisdiction requires an amount in controversy of at least $50,000 (exclusive of interest and costs), assessed from the complaint at the time of removal.
- In MMWA vehicle warranty cases seeking rescission or similar relief, the contract price may satisfy the jurisdictional threshold, subject to recognized offset concepts (including use value) when applicable.
- Summary judgment is appropriate when the nonmoving party lacks evidence on an essential element and fails to create a genuine issue of material fact.
- Federal Rule of Civil Procedure 61 requires courts to disregard errors that do not affect substantial rights; evidentiary defects at summary judgment do not warrant reversal absent a showing of prejudice affecting the outcome.

## Conclusion

The Sixth Circuit affirmed federal jurisdiction and summary judgment for the manufacturer, holding that the complaint satisfied the MMWA’s $50,000 threshold, the plaintiff failed to counter the manufacturer’s evidence of only minor or non-covered defects, and any Rule 56 evidentiary defect was harmless under Rule 61 because it caused no prejudice.


Harnden v. Jayco, Inc., 496 F.3d 579 (6th Cir. 2007)