Leticia Rivera v. American Honda Motor Co., Inc.
1:24-cv-12883
N.D. Ill.May 5, 2025Background
- Leticia Rivera purchased a 2020 Honda Pilot and alleges it had a defective infotainment system that caused audio issues and display malfunctions.
- Rivera repeatedly sought repairs at Honda dealerships, but the problem persisted until Honda issued an NHTSA recall in June 2023, after the litigation had begun.
- Rivera received a free repair under the recall, which resolved her issues. She later totaled her vehicle in an accident and received full market value from her insurer, State Farm.
- Rivera brought a putative class action against American Honda Motor Co., Inc., asserting claims under Illinois law for violation of the Illinois Consumer Fraud Act (ICFA), unjust enrichment, and breach of express warranty, seeking monetary and injunctive relief.
- Honda moved to dismiss the claims under Rule 12(b)(1) for lack of subject matter jurisdiction, arguing Rivera lacked standing after the recall and insurance payout.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing for Damages | Suffered overpayment injury at sale | Recall and insurance payout fully redress injury | Standing to pursue monetary damages; not moot |
| Standing for Injunctive Relief | Faces ongoing risk from defect | No ongoing risk; vehicle sold | No standing for injunctive relief; vehicle sold |
| Class Rep. for Injunctive Relief | Should represent class for injunction | Can’t represent for injunction w/o standing | Cannot represent class for injunctive relief |
| Insurance Payout’s Effect | Does not eliminate overpayment injury | Payout for full value negates overpayment | Does not defeat standing at the pleading stage |
Key Cases Cited
- Lujan v. Defs. of Wildlife, 504 U.S. 555 (standing requires injury in fact, traceability, and redressability)
- TransUnion LLC v. Ramirez, 594 U.S. 413 (standing must be shown for each claim and form of relief)
- Camasta v. Jos. A. Bank Clothiers, Inc., 761 F.3d 732 (past exposure to harm does not confer standing for injunctive relief)
- Avery v. State Farm Mut. Auto Ins. Co., 835 N.E.2d 801 (addressing damages upon transfer of defective vehicle in Illinois law)
- In re Aqua Dots Prods. Liab. Litig., 654 F.3d 748 (payment for defective product suffices for financial injury and standing)