Uddin v. Automobili Lamborghini America, LLC

Background

Salah Uddin alleged that several entities involved in the purchase, lease, and servicing of a custom-built 2020 Lamborghini Aventador violated the Truth in Mileage Act, breached express and implied warranties, violated California and federal consumer-protection laws, and committed negligence, fraud, and related torts. He alleged that the vehicle arrived at the dealership with operational, electronic, cosmetic, and authenticity problems. He also alleged that the paperwork listed conflicting mileage figures: 40 miles on the lease and odometer disclosure documents, and 30 miles on a dealership pre-delivery inspection record.

Uddin asserted nine claims against various defendants: Automobili Lamborghini America, LLC (ALA); Lamborghini North Los Angeles (LNLA); Lamborghini Financial Services, doing business as Porsche Financial Services (Porsche); and Lamborghini Westlake Village. The defendants separately moved to dismiss the second amended complaint under Federal Rule of Civil Procedure 12(b)(6), which requires dismissal when a complaint does not state a legally sufficient claim.

Truth in Mileage Act claim

The court dismissed Uddin’s mileage claim against LNLA for two independent reasons. First, the court held that the claim was subject to a three-year limitations period and accrued when Uddin received paperwork containing conflicting mileage figures on April 29, 2020. Because he did not file suit until April 26, 2024, the discovery rule did not preserve the claim. Second, the court held that the allegations did not plausibly show that LNLA intended to defraud Uddin. The court characterized the alleged overstatement of mileage as a clerical error rather than fraud.

The court also dismissed the mileage claim against Porsche. Uddin did not allege that Porsche misrepresented or concealed the vehicle’s mileage, knew what the odometer showed, or ever possessed the vehicle. The court concluded that Porsche’s alleged failure to take corrective action did not state a claim under the mileage statute.

Express-warranty claims

The court dismissed Uddin’s express-warranty claims against ALA and LNLA. As to ALA, the court concluded that Uddin plausibly alleged that the warranty began prematurely, but he did not adequately allege resulting damages or a substantial impairment of the vehicle’s use, value, or safety. The court also found that the warranty did not promise perfect delivery, on-time delivery, or completion of the other alleged repairs and services.

As to LNLA, the court held that LNLA could not be liable for breach of the express warranty because the warranty identified ALA as the warrantor and LNLA was not a party to that warranty. The court also treated duplicative express-warranty allegations under the Song-Beverly Consumer Warranty Act as part of another claim rather than allowing them to proceed separately.

Implied-warranty claims

The court dismissed the implied warranty of merchantability claim against all defendants. That warranty requires goods to be reasonably suitable for ordinary use. The court found that the vehicle’s initial starting and electronic problems were eventually repaired and that the remaining problems were primarily cosmetic or documentation-related. Those problems could affect the vehicle as a collectible but did not make it unfit for ordinary transportation.

The court denied the motions to dismiss Uddin’s claim for breach of the implied warranty of fitness for a particular purpose as to ALA and LNLA. Uddin alleged that, before the transaction, he told representatives that he intended to use the vehicle as a high-value collectible and that he relied on ALA’s and LNLA’s expertise in selecting its specifications. The court found those allegations plausible. The claim could proceed against ALA and LNLA as one claim under California law. The court did not allow it to proceed against the other defendants.

Tort claims

The court dismissed Uddin’s tort claims against ALA, LNLA, and Porsche. Uddin sought only economic losses, such as diminished vehicle value, repair-related losses, loss of use, and time and effort. The court held that the economic loss rule generally bars tort recovery for such losses absent an applicable exception.

The court rejected Uddin’s argument that a special relationship with ALA allowed his claims to proceed, finding that Uddin and ALA had a direct contractual relationship through the new-car warranty. The court also held that Uddin’s claims against LNLA and Porsche were based on the same contractual or mileage-related facts and did not establish an independent basis for tort liability. The court further stated that the misrepresentation and fraud claims against ALA lacked the particularized allegations required for fraud claims.

Disposition

The court granted in part and denied in part the motions to dismiss. The motions were granted on all claims except the implied-warranty-of-fitness claim that may proceed against ALA and LNLA. Because no cognizable claims remained against Porsche, the court dismissed Porsche from the case. The order did not state that any dismissal was with or without prejudice.