Wyatt v. CMH Manufacturing, Inc., 7:23-cv-00703

James Wyatt and Savanah Wyatt purchased a mobile home in February 2017 from Warrior Wholesale Homes, manufactured by CMH Manufacturing.
The home came with a one-year limited warranty from CMH Manufacturing, covering manufacturing defects, with all implied warranties also limited to one year.
The Wyatts reported and had repairs done under the warranty; repairs were completed satisfactorily during the warranty period.
Major roof leaks and water intrusion were first noticed by the Wyatts in late 2018, several months after all warranties expired; the leak persisted despite repairs by others and by contacting the manufacturer and retailer in November 2019.
The Wyatts filed suit asserting Magnuson-Moss Act (federal warranty) and state law claims; the case was removed to federal court, where defendants sought summary judgment and to strike expert evidence.
The court granted summary judgment on federal warranty claims and remanded state law claims to state court, declining supplemental jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Magnuson-Moss Act Breach of Warranty	Wyatts assert leaks breached express/implied warranties; claim timely notice of water damage within 6 months of occupancy.	Warranties limited to 1 year and all issues reported within timeframe were properly repaired; notice of roof leak came after warranties expired.	Defendants granted summary judgment; Wyatts gave notice of major leak after warranty expired; no breach.
Fictitious Defendant Claims	Magnuson-Moss Act claims extend to unnamed defendants.	Wyatts’ descriptions of fictitious defendants too vague for service.	Dismissed without prejudice; insufficient specificity.
State Law Claims	State claims should proceed with or without federal claims.	No argument cited (motions for summary judgment filed).	Remanded to state court; no supplemental jurisdiction exercised.
Motions to Strike Expert Evidence	N/A	N/A	Denied as moot; expert evidence not relevant to decision.

Patterson v. Ga. Pac., LLC, 38 F.4th 1336 (11th Cir. 2022) (summary judgment standard requires inferences in non-movant's favor)
Cantu v. City of Dothan, 974 F.3d 1217 (11th Cir. 2020) (summary judgment facts need not be actual historical facts)
Turner v. Westhampton Ct., LLC, 903 So. 2d 82 (Ala. 2004) (warrantors may limit warranty duration and require notice within that period)
Richardson v. Johnson, 598 F.3d 734 (11th Cir. 2010) (fictitious-party pleading generally not permitted unless defendant is adequately described)
Dean v. Barber, 951 F.2d 1210 (11th Cir. 1992) (details required for fictitious defendant pleading under federal practice)
Looney v. Moore, 886 F.3d 1058 (11th Cir. 2018) (material fact disputes preclude summary judgment)
Ex parte Miller, 693 So. 2d 1372 (Ala. 1997) (plaintiff must show warrantor failed to repair or replace as required to rebut warranty limitations)