On Tuesday, July 31, 2012, the U.S. District Court for the District of Minnesota denied class certification to a putative class of owners and lessees of Ford Freestar and Mercury Monterey minivans who brought suit against Ford Motor Company for alleged transmission failures in their 2004-2006 minivan models. Plaintiffs alleged that the transmission failures were caused by a defective design in the minivans’ torque converters, a component that acts as a bridge between the engine and the transmission. Plaintiffs argued that Ford’s failure to disclose a defect in the torque converters resulted in purchases or leases of the class vehicles at a higher price than Plaintiffs would have purchased or leased the vehicles had they known of the defect.
In denying class certification, the court held that the named plaintiffs could not demonstrate that their action was an appropriate class action under Federal Rule of Civil Procedure 23(b)(3). Specifically, the court held that Plaintiffs’ breach of warranty claims required individualized poof, particularly because: (1) the express warranty upon which Plaintiffs relied was limited and individual proof was required with respect to the question of whether the warranty was in effect for each class member; and (2) the implied warranty claim was dependent upon when the class member purchased the vehicle or the vehicle’s mileage at the time of purchase. The court further held that adjudication of Plaintiffs’ implied warranty claims by way of class certification was not warranted because implied warranty laws differed in the three states in which Plaintiffs sought to certify subclasses: Minnesota, Maryland, and Florida. The court also rejected Plaintiffs’ unjust enrichment claims and held that elements of an unjust enrichment claim cannot be proven through class-wide evidence and, therefore, individual issues predominate.
In addition to denying class certification, the court granted Ford’s Motion for Summary Judgment on Plaintiffs’ express and implied warranty and unjust enrichment claims. Please see the opinion, Diagle v. Ford Moto Co., Case No. 09-CV-3214 (MJD/LIB) (July 31, 2012), for additional details.