William McKitrick and Amy McKitrick v. Chrysler Group, LLC

Summary

The West Virginia Supreme Court of Appeals affirmed summary judgment for Chrysler Group, LLC, in a vehicle warranty action arising from the destruction of the plaintiffs’ Jeep Liberty by fire. The court held that, without expert testimony or other evidence identifying the cause of the fire, the plaintiffs’ circumstantial evidence would leave a jury to guess at the alleged warranty breach. The court distinguished a prior case involving a vehicle with documented electrical problems and repair attempts preceding the fire.

Holdings

1. Summary judgment for Chrysler was proper because the McKitricks presented no direct evidence, expert testimony, or other evidence identifying a warrantable defect or the cause of the fire, and their circumstantial evidence would require a jury to guess at the cause of the alleged breach.
2. A circuit court's order granting summary judgment is reviewed de novo.

Questions Presented

1. Whether the circuit court properly granted summary judgment where the plaintiffs relied on circumstantial evidence to prove that a defect covered by the vehicle's express or implied warranty caused the fire.
2. Whether the circumstantial evidence was sufficient to establish a breach of warranty without leaving the jury to speculate about the cause of the alleged breach.

Disposition

affirmed