RIAUBIA v. HYUNDAI MOTOR AMERICA
2:16-cv-05150
| E.D. Pa. | Aug 22, 2017Background
- Plaintiff Joshua Riaubia bought a 2015 Hyundai Sonata Limited (Aug. 2014) featuring a marketed "Smart Trunk" that allegedly opens wide enough for hands-free loading.
- Riaubia alleges the Smart Trunk often opens only a few inches or merely a crack, contrary to Hyundai Motor America (HMA) representations.
- He filed a putative class action (nationwide) asserting: California UCL, FAL, CLRA; Pennsylvania breach of express and implied warranties; Magnuson-Moss; and, alternatively, unjust enrichment.
- HMA moved to dismiss under Fed. R. Civ. P. 12(b)(6), arguing lack of standing to represent purchasers of different Hyundai models, failure to plead a defect/wrongful act, warranty bars, and that California law should not govern a nationwide class.
- The court accepted Riaubia’s factual allegations as true for purposes of the motion and denied HMA’s 12(b)(6) motion in full.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing to represent class of purchasers of different Hyundai models | Riaubia alleges his injury from the same non-conforming Smart Trunk feature that injured absent class members | HMA: named plaintiff lacks Article III standing to represent purchasers of different models | Court: Riaubia has Article III standing; adequacy/typicality are Rule 23 issues, not resolved at pleading stage |
| Whether Complaint pleads a defect / wrongful act under consumer-fraud and warranty claims | The Smart Trunk’s failure to open sufficiently as advertised plausibly breaches warranties and consumer-protection laws | HMA: trunk opens hands-free as advertised; subjective dissatisfaction is not a defect and written warranty limits remedies | Court: factual allegations plausibly state a defect; whether breach occurred is for the factfinder; claims survive 12(b)(6) |
| Effect of written limited warranty on extra-contractual remedies | Riaubia alleges repeated unsuccessful repairs/replacements, alleging warranty failed its essential purpose | HMA: warranty provides repair/replacement, which forecloses other relief | Court: warranty may be found to have failed its essential purpose — factual question for jury; cannot dismiss now |
| Pleading alternative unjust enrichment when contract exists | Riaubia may plead unjust enrichment in the alternative under Rule 8 | HMA: existence of an express warranty/contracts precludes unjust enrichment | Court: alternative unjust enrichment claim is permitted at pleading stage; survives dismissal |
| Choice-of-law for California claims / nationwide class | Riaubia asserts claims under California law for a nationwide class | HMA: California law shouldn’t apply nationwide; choice-of-law bars claims | Court: choice-of-law requires a factual record; premature to decide on motion to dismiss |
Key Cases Cited
- Phillips v. County of Allegheny, 515 F.3d 224 (3d Cir.) (pleading standard and accepting factual allegations at motion to dismiss)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must state plausibly actionable claim)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (facial plausibility standard for complaints)
- Neale v. Volvo Cars of N. Am., LLC, 794 F.3d 353 (3d Cir.) (named plaintiff may have standing to represent purchasers of different models when same defect/representations apply uniformly)
- Marcus v. BMW of N. Am., LLC, 687 F.3d 583 (3d Cir.) (typicality satisfied where misrepresentations apply across product types)
- Gratz v. Bollinger, 539 U.S. 244 (2003) (standing/adequacy discussion; majority rejected narrowing standing where differences don’t create significantly different concerns)
- In re Prudential Ins. Co. Sales Practices Litig., 148 F.3d 283 (3d Cir.) (distinguishing Article III standing from Rule 23 typicality/adequacy)