Maronyan v. Toyota Motor Sales, U.S.A., Inc., 2011 U.S. App. LEXIS 19258

Maronyan sued Toyota for breach of warranty and related claims under California law and the Magnuson-Moss Warranty Act (MMWA).
Toyota maintained a dispute-resolution mechanism (CDSP) that plaintiff allegedly had to use before pursuing suit under the MMWA.
District court dismissed for lack of subject-matter jurisdiction, holding failure to exhaust pre-suit remedies barred jurisdiction.
The issue is whether exhaustion under § 2310(a)(3) is a jurisdictional prerequisite or a prudential defense.
The Ninth Circuit holding addresses whether exhaustion affects subject-matter jurisdiction and how to proceed on remand.
The dissent would treat the exhaustion requirement as jurisdictional and assign primary-review to the FTC on mechanism compliance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether MMWA exhaustion is jurisdictional	Maronyan argues exhaustion is jurisdictional; but the majority says not.	Toyota argues exhaustion provides a jurisdictional bar.	Exhaustion is not jurisdictional; case remanded for merits with exhaustion issues
Who decides mechanism compliance under MMWA	Court should decide compliance; FTC not sole arbiter.	FTC has exclusive authority to determine compliance.	FTC should determine compliance; court defers pending FTC ruling on mechanism
Effect of incorporating exhaustion into jurisdictional provisions	Incorporation converts exhaustion into jurisdictional bar.	Incorporation clear predicate for jurisdictional effect.	Incorporation does tie exhaustion to jurisdiction; district court lacks jurisdiction until exhaustion

Reed Elsevier, Inc. v. Muchnick, 130 S. Ct. 1237 (U.S. 2010) (clarifies when exhaustion is jurisdictional; avoid drive-by rulings)
Arbaugh v. Y&H Corp., 546 U.S. 500 (U.S. 2006) (jurisdictional label requires clear congressional mandate)
Kontrick v. Ryan, 540 U.S. 443 (U.S. 2004) (defines when a requirement is jurisdictional for filing)