A federal judge has partially granted FCA US LLC’s motion for judgment on the pleadings against certain express warranty claims filed in a proposed class action lawsuit. The lawsuit alleges FCA US LLC breached its obligations under limited lifetime powertrain warranties for their 2006-2009 vehicles.
As detailed in the court’s order, the plaintiffs allege FCA’s predecessor (Chrysler LLC) sold its 2006-2009 Chrysler, Dodge, and Jeep-brand vehicles with a promise to repair or replace the powertrain components for the lifetime of the original registered owners. The plaintiffs claim FCA breached this lifetime powertrain limited warranty by refusing to repair or replace defective powertrain components.
At issue in the court’s order were plaintiffs’ request for relief under the theory of breach of warranty under the Uniform Commercial Code (UCC) express warranty provisions of the states where their respective vehicles were purchased.
FCA argued the UCC claims should be dismissed because the relevant “repair or replace” provisions in the Chrysler limited warranty did not create an express warranty under the Michigan UCC, and substantive Michigan law applied to those claims. The plaintiffs successfully argued, however, that there was a split in authority in the states involved in the case, and thus the court should apply the UCC warranty law of the state where the allegedly defective vehicle was purchased. Applying that rationale, the court granted judgment on the pleadings for FCA as to only four of the named plaintiffs, as those particular plaintiffs’ UCC express warranty claims would fail under the laws of their states (Illinois, Michigan, and Texas).
The case is Paul Grundy et al. v. FCA US LLC, case number 4:20-cv-11231, in the United States District Court for the Eastern District of Michigan.
You can read the order below:
