American Honda Motor Co. v. Superior Court
132 Cal. Rptr. 3d 91
Cal. Ct. App.2011Background
- Lee sued Honda in California state court, converted his action to a class action alleging breach of warranty and UCL regarding a defective third gear in 2002–2008 Acura models.
- Plaintiff sought class certification for all California purchasers/leasers of the affected models who had not installed the redesigned third gear.
- Honda moved to stay and the trial court certified the class, relying largely on Wolin v. Jaguar Land Rover North America LLC.
- Honda petitioned for writ of mandate arguing Wolin’s framework was inapplicable to California law and Hicks governs the defect showing for breach of warranty.
- The court held that the certification was based on an erroneous legal assumption and that the class did not present a common question of law/fact, warranting reversal of the certification order.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is mandamus available to challenge class certification? | Honda: mandamus appropriate due to erroneous certification ruling. | Lee: mandamus unnecessary; appeals post-judgment available. | Yes, writ is proper to review abuse of discretion. |
| Do common questions predominate for breach of warranty claims? | Lee: common defect and common proof predominate across class. | Honda: predominance exists under Wolin’s framework. | No; insufficient substantial evidence of common defect and predominance. |
| Was the trial court’s reliance on Wolin for breach of warranty proper? | Lee relied on Hicks to show inherent defect substantial to malfunction. | Wolin supports class certification for some warranty claims. | Unreasonable; Hicks controls in California law and Wolin inapplicable. |
| Do common questions predominate for the UCL claim? | Lee asserts uniform deceptive practices across class. | Representations varied by dealer and situation; not uniform. | No; no substantial common proof of misrepresentation. |
Key Cases Cited
- Blue Chip Stamps v. Superior Court, 421 F.3d 387 (Cal. 1976) (mandamus standards for remedy adequacy)
- Payne v. Superior Court, 17 Cal.3d 908 (Cal. 1976) (requirements for writ—duty and irreparable harm)
- Omaha Indemnity Co. v. Superior Court, 209 Cal.App.3d 1266 (Cal. App. 1989) (adequate remedy and irreparable harm in mandamus)
- Linder v. Thrifty Oil Co., 23 Cal.4th 429 (Cal. 2000) (great discretion on certification; need for substantial evidence)
- Washington Mutual Bank v. Superior Court, 24 Cal.4th 906 (Cal. 2001) (community of interest factors for class certification)
- Hicks v. Kaufman & Broad Home Corp., 89 Cal.App.4th 908 (Cal. App. 2001) (breach of warranty requires inherent defect substantially certain to malfunction)
- Wolin v. Jaguar Land Rover North America LLC, 617 F.3d 1168 (9th Cir. 2010) (predominance without requiring proof of current malfunction; federal framework)
- Daugherty v. American Honda Motor Co., Inc., 144 Cal.App.4th 824 (Cal. App. 2006) (breach of warranty requires showing defect manifests during useful life)
- Pfizer Inc. v. Superior Court, 182 Cal.App.4th 622 (Cal. App. 2010) (class action requirements in UCL context)
- Humberto S. v. People, 43 Cal.4th 737 (Cal. 2008) (abuse of discretion where error of law found)