Heath v. Guardian Interlock Network, Inc.

Summary

The Oklahoma Supreme Court affirmed summary judgment for Guardian Interlock in a class action concerning fees charged for an ignition interlock device. The court held that the $25 monthly maintenance-fee cap in 47 O.S. Supp. 2013 § 6-212.3 does not limit separate rental, tax, insurance, or damage-waiver fees. The court concluded that the statute’s plain language distinguishes maintenance charges from other fees.

Holdings

1. The $25 monthly maintenance-fee cap in 47 O.S. Supp. 2013 § 6-212.3 does not preclude providers from collecting other fees, including rental or lease fees, taxes, and insurance or damage-waiver fees.
2. The district court's grant of summary judgment to Guardian was proper because the undisputed charges identified by Heath were not all subject to the statutory maintenance-fee cap.

Questions Presented

1. Whether 47 O.S. Supp. 2013 § 6-212.3's $25 monthly cap on an ignition interlock device maintenance fee also limits rental or lease fees, taxes, and insurance or damage-waiver fees.
2. Whether the district court properly granted summary judgment to Guardian under the statute's interpretation.

Disposition

affirmed