Nilsen v. Tesla, Inc.

Background

Roald Nilsen purchased a used 2016 Tesla X on February 3, 2020. He alleged that the vehicle was delivered with serious defects and later developed additional defects involving its interior components, electrical system, and suspension system.

Nilsen originally asserted four claims. In earlier orders, the court dismissed his claims under California’s Song-Beverly Act and his claim for breach of express warranty under the California Commercial Code. The court left one claim pending: claim two of Nilsen’s First Amended Complaint, alleging a violation of the Magnuson-Moss Warranty Act (MMWA). The opinion states that this was the sole remaining claim.

Legal standard

The court applied Federal Rule of Civil Procedure 56. Summary judgment is appropriate when the evidence, viewed in the light most favorable to the nonmoving party, shows no genuine dispute about any material fact and establishes that the moving party is entitled to judgment as a matter of law. A material fact could affect the case’s outcome, and a genuine dispute exists when enough evidence would allow a reasonable factfinder to rule for the nonmoving party.

Discussion

The MMWA provides a federal cause of action for consumers claiming damages from a supplier’s, warrantor’s, or service contractor’s failure to comply with obligations under the statute, a written warranty, an implied warranty, or a service contract. The court explained, relying on Ninth Circuit authority, that an MMWA claim based on state-law warranties “stands or falls” with the underlying express- or implied-warranty claims under state law.

Nilsen’s remaining claim incorporated allegations from his Song-Beverly Act claim and alleged breach of express warranty. The court concluded that the MMWA claim therefore depended on the state-law claims that had already been dismissed. It rejected Nilsen’s argument that the MMWA was broader than state law, finding that argument inconsistent with binding Ninth Circuit authority.

Tesla raised additional arguments, including that it had not given Nilsen a warranty, that the vehicle had not been shown to violate the alleged warranty, that Nilsen had not submitted a required prelitigation claim, that he lacked contractual connection with Tesla to cancel the purchase, and that he had not pleaded recoverable damages. Because the court held that the MMWA claim failed as a matter of law based on the dismissal of the related state-law claims, it did not address those arguments.

Disposition

The court granted Tesla’s motion for summary judgment on claim two for violation of the Magnuson-Moss Warranty Act.