Wils of Faith Freight Uniters LLC v. Big Tex Trailer Manufacturing LLC
2:22-cv-01547
N.D. Ala.Dec 11, 2024Background
- Wils of Faith Freight Uniters, LLC purchased a Big Tex trailer in 2022, which came with a limited express warranty.
- The trailer’s axle failed while in use, and local authorized repair shops could not repair it; Wils received an oral $2,000 repair estimate from a non-authorized shop.
- Wils never submitted a formal written repair estimate to Big Tex and instead filed suit for breach of express warranty.
- Big Tex offered $3,000 to settle, which exceeded the only admissible repair cost evidence.
- The only remaining claim after summary judgment was for breach of express warranty, and the dispute centered on whether the case was moot given Big Tex’s offer and the warranty’s repair-or-replace limitation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the case is moot due to offer exceeding recoverable sum | Full relief requires trailer replacement cost | Liability is limited to repair, not replacement | The case is moot; remedy is limited to repair, and offer exceeded admissible claim value |
| Admissibility of 2024 repair estimate evidence | 2024 email estimate should be allowed | Only 2022 oral estimate is admissible | Only 2022 oral estimate admissible; 2024 estimate excluded |
| Entitlement to damages for mental anguish | Mental anguish damages recoverable | Not recoverable under Alabama law | No mental anguish damages available under relevant Alabama law |
| Entitlement to attorneys’ fees | Fees should be awarded in this case | No basis for attorneys' fees under law | No attorneys' fees; American Rule applies (each party bears its own fees) |
Key Cases Cited
- Ag-Chem Equip. Co. v. Limestone Farmers Co-op., 567 So. 2d 250 (Ala. 1990) (under a repair-or-replace warranty, manufacturer’s liability limited to cost of repair, not replacement)
- Djadju v. Vega, 32 F.4th 1102 (11th Cir. 2022) (action is moot when no live controversy remains and relief is unavailable)
- Christian Coal. of Fla., Inc. v. United States, 662 F.3d 1182 (11th Cir. 2011) (controversy must exist at all stages, not just at filing)
- United States v. Al-Arian, 514 F.3d 1184 (11th Cir. 2008) (mootness is jurisdictional and must be resolved before assuming jurisdiction)
- Barko Hydraulics, LLC v. Shepherd, 167 So. 3d 304 (Ala. 2014) (mental-anguish damages not generally available in breach-of-contract actions)