Hadley v. Chrysler Group, LLC, 624 F. App'x 374

Recall notice issued January 2013 for airbag ORC Module defect causing electrical overstress leading to possible inadvertent deployment; New Chrysler promised free, prompt repairs as quickly as possible.
Plaintiffs own a 2003 Jeep Grand Cherokee potentially affected by the defect; their vehicle’s airbag warning light illuminated but did not deploy.
Plaintiffs sue for damages against New Chrysler and TRW, plus declaratory and injunctive relief asserting a safety defect that must be repaired at no cost and as quickly as possible.
New Chrysler was formed in 2009 to acquire assets from Old Chrysler after bankruptcy; it assumed some liabilities but not all.
District court dismissed for lack of standing and mootness after New Chrysler acknowledged the defect, promised free repair, and repaired the plaintiffs’ vehicle; the plaintiffs appeal.
The panel affirms, holding plaintiffs lacked standing to seek damages and their injunctive/declaratory claims were moot following repair; any sought remedies would not affect the parties’ interests.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing requirement (injury-in-fact)	Plaintiffs suffered injuries (diagnostic costs, diminished value, lost use) traceable to Chrysler’s delay.	There was no concrete, injury-in-fact causally linked to New Chrysler’s delay; no redressable injury.	No standing; plaintiffs failed to show concrete, particularized injury traceable to the delay.
Mootness of injunctive and declaratory claims	Relief could still affect class members if repair effectiveness were uncertain.	Repair completed and defect acknowledged; relief would not alter legal interests.	Claims moot; district court properly dismissed declaratory and injunctive claims.
Rule 10(e) supplements to record	Proposed supplementary NHTSA reports support mootness arguments.	Rule 10(e) does not permit new evidence not considered below.	Motions to supplement record denied.
Scope of damages and liability relation to New Chrysler	Damages for delay in repair should be recoverable; New Chrysler sought to avoid liability by focusing on defect origin.	Liability centered on delay to repair; Old Chrysler manufactured the vehicle, and New Chrysler assumed only some liabilities.	Judge’s analysis affirmed; standing defeats damages claim.

Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requires injury in fact, causation, redressability)
Genesis Healthcare v. Symczyk, 133 S. Ct. 1523 (2013) (mootness and justiciability principles in class/individual actions)
McPherson v. Michigan High School Athletic Ass’n, Inc., 119 F.3d 453 (6th Cir. 1997) (standing standard and real-party-in-interest concepts)
Simon v. Eastern Kentucky Welfare Rights Organization, 426 U.S. 26 (1976) (class action standing requires personal injury to named plaintiffs)
PPG Indus., Inc. v. Indust. Laminates Corp., 664 F.2d 1332 (5th Cir. 1982) (redhibition concepts and injury principles in product defect context)
Cole v. General Motors Corp., 484 F.3d 717 (5th Cir. 2007) (distinguishes diminished-value injury when plaintiff is not the manufacturer)