Michael Tatsch v. Chrysler Group, LLC and Infinity County Mutual Insurance Company
04-13-00757-CV
| Tex. App. | Jan 30, 2015Background
- Appellant Michael Tatsch sued Chrysler, alleging breach of an express warranty for a Cummins diesel‑equipped vehicle after repairs were denied.
- The Warranty Information Booklet contains a Basic Limited Warranty (3 years/36,000 miles) and a Cummins Diesel Engine Limited Warranty (begins when Basic warranty ends; up to 5 years/100,000 miles) listed as a “Special Extended Warranty Coverage.”
- Section 2.2(B) of the booklet lists the specific engine parts covered by the Cummins Warranty.
- Section 3.3 (What’s Not Covered) excludes damage from poor/improper maintenance and use of contaminated or non‑recommended fuels, oils, lubricants, cleaners, or fluids.
- The Fourth Court of Appeals concluded the Cummins Warranty “makes no mention of the limiting defect language” and found there was some evidence of breach based on the listed parts; Chrysler moved for rehearing arguing that the appellate court misread the warranty as a whole.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Cummins Warranty requires proof of a manufacturing defect existing when the vehicle left the plant | Tatsch: inclusion of parts in Section 2.2(B) is sufficient evidence of breach under the Cummins Warranty | Chrysler: Cummins Warranty is an extension of the Basic Limited Warranty and therefore subject to same defect‑limiting terms (and exclusions in §3.3) | Appellate court held Cummins Warranty lacked the explicit defect‑limiting language and found some evidence of breach based on covered parts (Chrysler seeks rehearing) |
| Whether the Cummins Warranty imposes unconditional replacement obligations for listed parts | Tatsch: covered parts listed implies warranty obligations during Cummins period | Chrysler: no express obligation language in Cummins Warranty; only parts listed — obligations derive from Basic Limited Warranty terms, not unconditional coverage | Court treated listing as sufficient to support evidence of breach; Chrysler argues that reading yields an unreasonable, expanded obligation |
| Effect of §3.3 exclusions on warranty coverage | Tatsch: focused on listed parts and asserted breach during Cummins period | Chrysler: §3.3 bars coverage for failures caused by improper maintenance or contaminated/non‑recommended fluids, so plaintiff must prove absence of those causes | Court did not give dispositive weight to §3.3 in its opinion; Chrysler argues appellate court erred by failing to harmonize §3.3 with coverage provisions |
| Proper method of contract interpretation for the warranty booklet | Tatsch: relied on plain listing of covered parts in Cummins section | Chrysler: contract must be read as a whole; Frost/Med. City principles require harmonizing provisions and giving effect to specific limitations | Appellate court concluded Cummins listing created warranty coverage; Chrysler contends that full‑text interpretation would produce a different result and seeks rehearing |
Key Cases Cited
- Forbau v. Aetna Life Ins. Co., 876 S.W.2d 132 (Tex. 1994) (specific contract provisions limit general obligations)
- Frost Nat’l Bank v. L&F Distribs., 165 S.W.3d 310 (Tex. 2005) (contracts construed as a whole and from a utilitarian standpoint)
- Med. City Dallas, Ltd. v. Carlisle Corp., 251 S.W.3d 55 (Tex. 2008) (express warranties are contractual and interpreted under contract law)