Frankowski v. Ford Motor Company, 3:25-cv-02300

Kyle Frankowski filed a class action against Ford Motor Company in the Northern District of California, alleging that a defect in his 2021 Ford Bronco Sport caused the vehicle to catch fire.
The alleged defect involves fuel injectors prone to cracking and leaking in certain Ford Bronco Sport and Ford Escape models, leading to a fire risk.
Frankowski asserts claims under California consumer protection statutes and seeks certification of a nationwide class of affected vehicle owners or lessees.
A similar earlier case (Letson v. Ford Motor Co.) is pending in the Eastern District of Michigan, involving nearly identical factual allegations and claims, including a proposed nationwide class and California-specific subclasses.
Ford moved to transfer Frankowski’s case to Michigan under the first-to-file rule or, alternatively, for convenience under 28 U.S.C. § 1404(a).
The Letson case had already advanced through significant motion practice before Judge Shalina D. Kumar.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Applicability of First-to-File Rule	Rule should not apply because both cases are in early stages	Rule applies due to prior, similar case in Michigan	Rule applies; transfer warranted
Similarity of Parties	Not all named plaintiffs are identical (Frankowski not named in Letson)	Identity not required; putative classes are identical	Sufficient similarity for transfer
Similarity of Claims	Ford challenging standing of California plaintiffs in Letson; risk that claims will diverge	Both cases seek relief for same defect, same classes, same claims	Claim similarity is sufficient currently
Judicial Efficiency and Venue	No advancement in Letson warrants keeping the case in California	Michigan court’s experience will promote efficiency and avoid duplication	Efficiencies justify transfer

Alltrade, Inc. v. Uniweld Products, Inc., 946 F.2d 622 (9th Cir. 1991) (explaining the first-to-file rule’s purpose and discretionary nature)
Kohn Law Grp., Inc. v. Auto Parts Mfg. Mississippi, Inc., 787 F.3d 1237 (9th Cir. 2015) (describing factors for applying first-to-file rule)