557 P.3d 735
Cal.2024Background
- Plaintiffs (Rodriguez and Arellano) purchased a two-year-old Dodge Ram 2500 with over 55,000 miles from a used car dealership; the truck had an unexpired manufacturer’s powertrain warranty, though the bumper-to-bumper warranty had expired.
- The vehicle experienced persistent engine problems, resulting in multiple repair attempts by FCA’s authorized facilities.
- Plaintiffs sued FCA under the Song-Beverly Consumer Warranty Act, seeking the refund-or-replace remedy for "new motor vehicles".
- FCA argued that vehicles sold as used with unexpired manufacturer warranties are not "new motor vehicles" under section 1793.22, subdivision (e)(2).
- The trial court granted FCA summary judgment; the Court of Appeal affirmed, excluding used vehicles with remaining warranties from the “new motor vehicle” definition under the Act.
- The California Supreme Court granted review to address the proper interpretation of “other motor vehicle sold with a manufacturer’s new car warranty.”
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Definition of “new motor vehicle” under Song-Beverly Act | Any vehicle sold with a balance of the original manufacturer’s new car warranty qualifies | Only vehicles for which a manufacturer’s new car warranty is issued with the sale qualify | "Other motor vehicle sold with a manufacturer's new car warranty" means the warranty is issued at sale, not just transferred |
| Application to Used Vehicles | Used cars with unexpired warranties should get full Act protections | Act’s remedies for used cars are limited; manufacturer not liable unless new warranty is issued at sale | Used vehicles with merely unexpired original warranties do not qualify for the refund-or-replace remedy |
| Legislative Intent | Legislature intended to expand protections to all cars with manufacturer warranties | Legislature maintained distinction between new and used; specific legislative language needed | No clear intent to cover all used cars with unexpired warranties; statute is limited as written |
| Precedential Interpretations (Jensen case) | Jensen extends Act protections to all cars with unexpired new car warranties | Jensen is factually distinct (warranty issued at lease); reasoning overly broad | Disapproves Jensen v. BMW to the extent it's inconsistent with current opinion |
Key Cases Cited
- Niedermeier v. FCA US, LLC, 15 Cal.5th 792 (Cal. 2024) (distinguishing Song-Beverly Act remedies from contract remedies)
- Kirzhner v. Mercedes-Benz USA, LLC, 9 Cal.5th 966 (Cal. 2020) (statutory construction—plain meaning rule)
- Robertson v. Fleetwood Travel Trailers of California, Inc., 144 Cal.App.4th 785 (Cal. Ct. App. 2006) (Song-Beverly’s remedial purpose)
- Ruiz Nunez v. FCA US LLC, 61 Cal.App.5th 385 (Cal. Ct. App. 2021) (distinction between warranties for new vs. used goods under Song-Beverly)