Don’t overlook fundamental legal principles when formulating your response in complex class action litigaiton. A federal judge in Minnesota recently applied three seemingly simple and straight forward legal principles – or perhaps better described as common sense propositions – to dismiss a class action brought against Ford Motor Co. In sending the claimants on their way, the judge found that an express warranty should be construed and applied as written; that a plaintiff must act within the time limits placed on, and satisfy the statutory requirements associated with implied warranty claims, and that where a defendant receives no benefit, there can be no unjust enrichment.
In a written order dismissing a warranty-based class action brought against Ford Motor Co., Judge Michael J. Davis of the U.S. District Court in Minnesota provides broad insight into ways to defeat claims of this type and a drill-down analysis of the legal theories involved (express warranty, implied warranty, and unjust enrichment) under the law of each of the three plaintiffs’ home states (Minnesota, Maryland, and Florida). Daigle et al. v. Ford Motor Co. (Case No. 09-cv-03214).
Express Warranty: The Minnesota plaintiff argued that his vehicle was defective when purchased, but that the defect did not manifest until after his express warranty (New Vehicle Warranty) had expired. The court refused to accept this argument, pointing out that creating such a rule would render any warranty limited in time or mileage meaningless. The Maryland and Florida plaintiffs added a wrinkle to their arguments by claiming that Ford advertisements served to create an express warranty in the vehicles. The court swiftly shot down this argument, explaining that none of the Ford advertisements had expressly warranted against defects and the advertisements were merely an “affirmation of the value of goods.”
Implied Warranty: Judge Davis quickly disposed of all three implied warranty claims. Any implied warranties given to the Minnesota plaintiff ended along with the express warranty (New Vehicle Warranty) and were thereafter disclaimed. For the Maryland plaintiff, the applicable four-year statute of limitations had already run. Florida law requires privity between the manufacturer and the buyer in order for the buyer to bring an implied warranty claim; because the Florida plaintiff purchased his vehicle as used car, his claim fails.
Unjust Enrichment: The Maryland plaintiff’s claim failed because, under Maryland law, a claimant may not assert an unjust enrichment claim where the subject matter of the claim is covered by an express contract between the parties. The court disposed of the Minnesota and Florida plaintiffs’ claims because both plaintiffs had purchased used vehicles and there was no evidence that Ford benefitted from their purchase of the used vehicles.
Judge Davis also denied class certification to the plaintiffs purporting to represent all owners and lessees of 2004 to 2006 Ford Freestar and Mercury Monterey vehicles.