Mendoza v. Tesla, Inc.
- Vince Chhabria
- 3:24-cv-08738
- U.S. District Court · Northern District of California
- 3
In Mendoza v. Tesla, Judge Chhabria partly granted Tesla’s motion for judgment on the pleadings, allowing misrepresentation claims to proceed and granting it as to concealment.
Caleb Mendoza and the other plaintiffs may continue pursuing the misrepresentation claims, while the concealment claim was subject to the court’s ruling and may be addressed through an amended complaint. Tesla must respond to any amended complaint, and discovery on the surviving claims may proceed.
What happened
In Mendoza v. Tesla, Inc., Caleb Mendoza and other plaintiffs challenged Tesla statements about its Autopilot system and self-driving technology.
The court found that the complaint plausibly alleged misleading statements and reliance on at least the Autopilot name, but did not adequately allege that Tesla had a duty to disclose information. The court also said evidence would be needed to show reliance on statements other than the Autopilot name.
Judge Vince Chhabria granted the motion in part as to the concealment claim and denied it in part as to the misrepresentation claims. The plaintiffs may amend within 14 days, and discovery on the surviving claims may begin immediately.
The detailed version
- Mendoza v. Tesla, Inc. · No. 3:24-cv-08738
- Vince Chhabria
- May 16, 2025
Background
The plaintiffs asserted misrepresentation and concealment claims concerning Tesla’s statements and the name “Autopilot.” Tesla moved for judgment on the pleadings, which asks the court to rule based on the parties’ pleadings rather than evidence developed through a trial.
Misrepresentation Claims
The court denied the motion as to the misrepresentation claims. It held that the complaint plausibly alleged actionable misrepresentations, including the “Autopilot” name, statements that Autopilot was “probably better” than a human driver, and a statement that autonomous driving was “basically a solved problem.” The court also found that the complaint alleged reliance on at least one of those misrepresentations.
The court said predictions about future events can support a fraud claim when the speaker presents himself as specially qualified and the listener may reasonably rely on his superior knowledge. Based on the allegations, the court found it reasonable to infer that Elon Musk had special knowledge about self-driving technology and that consumers might reasonably rely on his predictions.
The court also noted a pleading problem: the complaint did not specify which statements, other than the Autopilot name, Mendoza relied on. If the plaintiffs seek to use other statements at summary judgment or trial, they will need evidence that Mendoza relied on those particular statements.
Concealment Claim
The court granted the motion as to the concealment claim because the plaintiffs had not adequately alleged that Tesla had a duty to disclose material information to Mendoza. The court distinguished between a misleading half-truth, which may create a duty to provide additional information, and the plaintiffs’ allegation that the Autopilot name was simply a lie that supported their misrepresentation claims.
Disposition
The order granted in part and denied in part Tesla’s motion for judgment on the pleadings: it was granted as to the concealment claim and denied as to the misrepresentation claims. The plaintiffs have leave to amend to allege facts supporting a duty to disclose. Any amended complaint is due within 14 days of the order, with a response due 14 days later. The court also allowed discovery on the surviving claims to proceed immediately.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.