RIAUBIA v. HYUNDAI MOTOR AMERICA
2:16-cv-05150
| E.D. Pa. | Aug 7, 2019Background
- Plaintiff Joshua Riaubia bought a 2015 Hyundai Sonata with a Smart Trunk feature and alleges the hands-free trunk fails to open fully due to a torsion-bar defect; he filed a nationwide class action for model years 2015–2017.
- Defendant Hyundai Motor America moved to dismiss; the motion was denied and the parties engaged in two mediated sessions, culminating in a settlement term sheet and a proposed Settlement Agreement.
- The proposed Settlement Class includes current and former owners/lessees of the U.S.-spec 2015–2017 Sonatas with Smart Trunk, excluding various affiliates, prior releasers, opt-outs, and certain damage claimants.
- Settlement relief: a choice of $50 debit card or $100 dealer credit, parts replacement (with a second replacement if needed), warranty extension, and reimbursement for prior repairs; Hyundai will administer notice and claims.
- The Magistrate Judge conducted a preliminary fairness evaluation, addressing Rule 23(a), Rule 23(b)(3), ascertainability, notice adequacy, and appointment of class counsel, and recommended preliminary approval and certification for settlement purposes.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the proposed class meets Rule 23(a) requirements (numerosity, commonality, typicality, adequacy) | Riaubia: ~30,000 vehicles; common defect (torsion bar) and identical warranties; representative’s claims align with class; counsel are experienced | Hyundai: (not elaborated in opinion because settlement is unopposed) | Court preliminarily found Rule 23(a) satisfied — numerosity, commonality, typicality, and adequacy met |
| Whether the class meets Rule 23(b)(3) (predominance and superiority) | Riaubia: liability turns on Hyundai’s common conduct; class action is superior because individual claims are small and joinder impracticable | Hyundai: (no contested argument presented at preliminary approval) | Court found predominance and superiority satisfied for settlement certification |
| Whether the class is ascertainable | Riaubia: objective criteria (model years, Smart Trunk) and VIN records make identification administratively feasible | Hyundai: (not disputed) | Court found the class ascertainable using VINs and sales records |
| Whether the proposed settlement, notice, and counsel appointment are appropriate for preliminary approval | Riaubia: negotiations were arm’s-length with mediation; sufficient discovery; notices (mail + website) meet Rule 23; proposed counsel meet Rule 23(g) factors | Hyundai: did not oppose preliminary approval | Court concluded the settlement appears fair, reasonable, and adequate for preliminary approval; notice procedures and class counsel appointment approved |
Key Cases Cited
- In re Nat’l Football League Players Concussion Injury Litig., 775 F.3d 570 (3d Cir. 2014) (two-step review of class settlement and guidance on preliminary certification for notice)
- Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338 (2011) (commonality standard for class actions)
- Marcus v. BMW of N. Am., LLC, 687 F.3d 583 (3d Cir. 2012) (ascertainability and typicality analysis in automobile defect class actions)
- Amchem Prods., Inc. v. Windsor, 521 U.S. 591 (1997) (standards for settlement-only class certification and adequacy matters)
- In re Warfarin Sodium Antitrust Litig., 391 F.3d 516 (3d Cir. 2004) (typicality and predominance in class actions)
- Sullivan v. DB Invs., Inc., 667 F.3d 273 (3d Cir. 2011) (predominance inquiry focuses on whether defendant’s conduct was common to the class)
- In re Prudential Ins. Co. Am. Sales Practice Litig., 148 F.3d 283 (3d Cir. 1998) (notice and fairness presumption where counsel are experienced and negotiations are arm’s-length)
- Girsh v. Jepson, 521 F.2d 153 (3d Cir. 1975) (district court discretion in approving class settlements)