Shawn Petro, et al., on behalf of themselves and all others similarly situated v. FCA US LLC

Summary

The United States District Court for the District of Delaware addresses FCA US LLC’s partial motion to dismiss claims arising from alleged valve-train defects in certain HEMI-engine vehicles. The court holds that plaintiffs sufficiently state express-warranty claims, dismisses their unjust-enrichment claims without prejudice, and dismisses their nationwide class allegations for lack of standing. The motion is granted in part and denied in part.

Holdings

1. The Second Amended Complaint plausibly stated express-warranty claims because Plaintiffs alleged specific manufacturing defects in addition to the alleged design defect, and those allegations supported a reasonable inference that FCA breached the express warranties.
2. Plaintiffs plausibly stated breach-of-express-warranty claims by alleging unsuccessful repair attempts and out-of-pocket repair costs.
3. The court declined to dismiss the express-warranty claims as time-barred because fraudulent concealment plausibly tolled the statute of limitations, consistent with the court’s prior ruling in the action.
4. The unjust-enrichment claims could not survive because the alleged existence of express warranties left no doubt regarding the existence of the relevant contracts; the claims were dismissed without prejudice.
5. Plaintiffs lacked standing to pursue claims on behalf of a nationwide class where adjudication would require applying the substantive laws of states in which Plaintiffs did not reside; the nationwide class allegations were dismissed.

Questions Presented

1. Whether Plaintiffs plausibly stated breach-of-express-warranty claims by alleging manufacturing defects, unsuccessful repairs, and out-of-pocket repair expenses.
2. Whether Plaintiffs’ express-warranty claims were barred by the statute of limitations at the pleading stage.
3. Whether Plaintiffs could maintain unjust-enrichment claims in the alternative when the existence of express warranties was alleged and undisputed.
4. Whether Plaintiffs had standing to pursue nationwide class allegations involving claims arising under the substantive laws of states where Plaintiffs did not reside.

Disposition

other