REINKRAUT v. FCA US LLC
2:23-cv-02792
| D.N.J. | Jun 29, 2025Background
- Plaintiffs, a group of Jeep vehicle owners and lessees across several states, allege that their vehicles (Wrangler, Gladiator, Grand Cherokee, certain years) have defective windshields prone to cracking, chipping, or fracturing under normal use, sometimes shortly after purchase.
- Plaintiffs claim FCA US LLC (the defendant) was aware of and failed to disclose or remedy the Windshield Defect, despite advertising their vehicles as safe and durable.
- Plaintiffs seek relief under various theories, including state consumer protection statutes, breach of warranty, fraud, unjust enrichment, and negligent misrepresentation.
- The case comes before the court on FCA’s motion to dismiss the Third Amended Complaint (TAC), following earlier motions and amendments.
- The court evaluates both standing and sufficiency of the plaintiffs’ pleadings under Rules 12(b)(1), 12(b)(6), and 9(b), focusing on whether the pleadings support plausible, particularized claims.
- Plaintiffs concede they lack standing for a nationwide class and for a Magnuson-Moss Warranty Act claim and limit claims to states with named plaintiffs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing for Nationwide Class | Plaintiffs concede lack of standing for nationwide class claims | Plaintiffs lack standing for nationwide class | Motion granted: Only state subclasses where a named plaintiff resides can proceed |
| Adequacy of Fraud & Statutory Consumer Claims | FCA failed to disclose or concealed defect; marketing materials misleading | Generalized statements not actionable; no duty to disclose; claims not pled with sufficient particularity | Most state consumer protection/fraud claims dismissed with prejudice for insufficient pleading |
| Breach of Magnuson-Moss Warranty Act | Plaintiffs lack 100-plaintiff threshold | Argue dismissal required by statute | Claim dismissed with prejudice |
| Viability of Common Law & Certain Warranty Claims | Complaint amendments permit plausibility on common law claims (fraud, warranty, unjust enrichment) | Dismissal argued, but no choice-of-law determination yet | Motion denied as to common law claims; they survive at this stage |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for Rule 12(b)(6) motions)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standard under Rule 12(b)(6))
- Mortensen v. First Fed. Sav. & Loan Ass'n, 549 F.2d 884 (Rule 12(b)(1) subject matter jurisdiction: facial and factual attacks)
- Fowler v. UPMC Shadyside, 578 F.3d 203 (separating factual and legal allegations in pleading sufficiency analysis)
- Burtch v. Milberg Factors, Inc., 662 F.3d 212 (legal conclusions not entitled to truth presumption in pleadings)
- Kehr Packages, Inc. v. Fidelcor, Inc., 926 F.2d 1406 (plaintiff bears burden on standing challenges)
- Ballentine v. United States, 486 F.3d 806 (standing as jurisdictional under Rule 12(b)(1))