Court Dismisses Diesel Engine Defect Case Against Manufacturers FCA and Cummins

On Tuesday, a motion to dismiss was granted by judge in the Eastern District of Michigan in a class action lawsuit against FCA US LLC. FCA, which owns the car brand Ram, was accused of putting defective motors in their 2019 and 2020 Ram 2500, 3500, 4500, and 5500 Heavy Duty trucks. The plaintiffs claim that this error violated the Magnuson-Moss Warranty Act and “common law breach of contract, as well as claims under the laws of 18 different States for unjust enrichment, breach of implied warranty of merchantability, and/or violation of consumer-protection statutes.”

The vehicles were recalled after the defendant was made aware of the issue, but before the plaintiffs experienced engine failure, the opinion said. While all of these issues were covered by a warranty, the plaintiffs claimed that they suffered damages by losing the benefit of the bargain – the market value of the vehicle was lower than expected upon purchase because of these defects.

The court acknowledged that the plaintiffs were accurate in alleging an economic injury, aside from one plaintiff who filed a claim for his 2018 model. The court ruled that there is no real evidence to suggest that the 2018 model is defective, and that it is just conjecture.

Ultimately, the case was dismissed on account of the doctrine of prudential mootness. The court reasoned that the plaintiffs allege no facts to support their assertion that “there is no known fix” or that the repairs will not provide them with the vehicles they bargained for. Their claim that the repairs and recall would not resolve the issues was based only in hypotheticals, and nothing else, the opinion said.

Lastly, the court stated that they “can offer little by way of an injunction or declaratory relief that will not already be provided through the recall. Further, the anticipated repairs will remove the defect upon which Plaintiffs’ claim for benefit-of-the-bargain damages is based” and that this evidence is insufficient to move forward with the case.

The plaintiffs were represented by Hagens Berman Sobol Shapiro,The Miller Law Firm, and Hilliard Martinez Gonzales. FCA was represented by Thompson Coburn and King & Murray. Codefendant engine manufacturer Cummins was represented by Barnes & Thornburg.