Paris Limousine of Oklahoma, LLC v. Executive Coach Builders, Inc.
2017 U.S. App. LEXIS 14477
| 8th Cir. | 2017Background
- Paris Limousine purchased nine limousines from Executive Coach that were converted from standard vehicles.
- Executive Coach allegedly expressly warranted the vehicles complied with all applicable Federal Motor Vehicle Safety Standards (FMVSS).
- The vehicles’ actual weights exceeded the weight ratings on the FMVSS-required labels; Paris alleges the cars are therefore uncertified and unsafe and require physical modification to comply.
- Paris sued for breach of express (and implied) warranty and Magnuson-Moss violations; the district court granted Executive Coach’s motion to dismiss the express-warranty claim as an improper attempt to enforce FMVSS, and denied reconsideration.
- On appeal, the Eighth Circuit reviewed the dismissal de novo and considered whether state-law warranty claims are barred because FMVSS contain no private right of action or are preempted by federal law.
- The Court reversed the dismissal and remanded, holding Paris may pursue its express warranty claim under state law despite the lack of a private right to enforce FMVSS.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a state-law express warranty claim is barred because FMVSS lack a private right of action | Warranty obligations are independent of FMVSS; Paris can enforce Executive Coach’s express warranty under Missouri law | Paris is trying to circumvent the FMVSS’s lack of private enforcement by using a warranty claim | Held for Paris: Safety Act expressly preserves warranty remedies; state warranty claim not barred by absence of FMVSS private right of action |
| Whether federal conflict preemption bars Paris’s warranty claim | No preemption; warranty claim can coexist with FMVSS objectives | Warranty claim conflicts with FMVSS or frustrates federal objectives | Court: Defendant failed to meet burden to show impossibility or obstacle preemption; no proven conflict |
| Whether Paris pleaded legally cognizable damages for breach of warranty | Alleged loss of benefit of the bargain because vehicles are overweight and mislabeled | Argued damages were not adequately alleged | Held for Paris: Complaint sufficiently alleges lack of full use and benefit; damages pleaded adequately |
| Whether Astra v. Santa Clara controls to bar state-law claims grounded on federal standards | N/A (Paris relies on Safety Act’s savings clause) | Astra shows federal statute can preclude indirect enforcement of federal standards | Court: Astra is inapposite because Public Health Service Act lacks Safety Act’s savings clause preserving warranty remedies |
Key Cases Cited
- Zutz v. Nelson, 601 F.3d 842 (8th Cir. 2010) (pleading facts drawn from complaint on motion to dismiss)
- Geier v. Am. Honda Motor Co., 529 U.S. 861 (2000) (preemption framework and obstacle preemption principles)
- Ayres v. Gen. Motors Corp., 234 F.3d 514 (11th Cir. 2000) (FMVSS contains no private right of action)
- Fabian v. Fulmer Helmets, Inc., 628 F.3d 278 (6th Cir. 2010) (state-law warranty/misrepresentation claims not barred by Safety Act when authorized by state law)
- Astra USA, Inc. v. Santa Clara County, 563 U.S. 110 (2011) (distinguishable: statute there lacked a savings clause preserving state remedies)
- Coghlan v. Wellcraft Marine Corp., 240 F.3d 449 (5th Cir. 2001) (damages for loss of benefit of the bargain in warranty contexts)