Uddin v. Automobili Lamborghini America

Background

Salah Uddin purchased a 2020 Lamborghini Aventador SVJ Roadster for his car collection. The vehicle was an allocation-based, custom-built vehicle configured through Lamborghini’s Ad Personam customization program. Uddin described his intended use as collecting and preserving the vehicle in new, factory-original condition, with agreed customization, matching numbers, and intact factory provenance.

Uddin inspected the vehicle before signing the lease. He identified problems including a vehicle that initially would not run, damage to the engine cover and other components, damaged or incomplete authenticity labels, and a missing carbon-skin interior feature. He nevertheless signed the lease after receiving assurances that the defendants would repair or address the problems and provide related documentation. Afterward, the parties continued discussing repairs and replacement parts.

Uddin later challenged records listing the vehicle’s mileage as 40 miles, while other records and the vehicle’s odometer indicated 30 miles. After the lease ended, he purchased the vehicle. His only remaining claim was for breach of the implied warranty of fitness for a particular purpose. The court had previously dismissed his other claims.

Motions and Legal Standards

Automobili Lamborghini America, LLC (ALA) moved for summary judgment. Boardwalk Automobiles Palo Alto, LLC, formerly known as Lamborghini North Los Angeles, moved to join ALA’s motion. The court granted the joinder because the defendants were similarly situated and ALA’s arguments applied equally to Boardwalk.

Summary judgment is appropriate when the evidence shows no genuine dispute over a fact that could affect the result and the moving party is entitled to judgment under the law. The court must draw reasonable factual inferences for the party opposing the motion, but speculation and conclusory testimony are not enough to require a trial.

Under California law, an implied warranty of fitness for a particular purpose generally requires proof that the buyer intended a particular use, the seller knew or had reason to know of that use, the buyer relied on the seller’s skill or judgment in selecting or furnishing suitable goods, and the seller knew or had reason to know of that reliance.

Statute of Limitations and Governing Law

The court rejected ALA’s argument that Uddin’s claim was untimely. Under the California Commercial Code, a warranty claim generally must be filed within four years after delivery. The court concluded that Uddin filed within that period, so the statute of limitations did not independently support summary judgment.

The court also concluded that the Song-Beverly Consumer Warranty Act applied because the vehicle was a consumer good. The court found no evidence that the defendants sold it on an “as is” or “with all faults” basis. It therefore rejected ALA’s argument that Uddin’s inspections before entering the lease barred his implied-warranty claim.

Particular Purpose

The court explained that a particular purpose must be a specific use that differs from the ordinary use of the product. The parties agreed that Uddin bought the vehicle as a collectible. The court accepted that the vehicle was generally a collectible but held that Uddin’s more specific definition of collectability was not legally cognizable for this warranty claim.

Uddin’s asserted purpose included maximizing the vehicle’s collectability, value, future appreciation, provenance, and preservation in factory-built condition. The court reasoned that collectability and future appreciation depend on market forces and involve speculation. It also noted that several features Uddin considered essential, including matching numbers and the mileage information, had not been expressly communicated to ALA and instead were treated by Uddin as implied by his status as a collector.

The court separately concluded that the 10-mile difference between the mileage listed in some documents and the vehicle’s actual mileage was insubstantial. Because Uddin confirmed that the correct mileage was 30 miles, the discrepancy did not establish a breach of the implied warranty for a particular purpose.

Skill and Judgment

The court held that Uddin’s claim also failed because he could not show the required reliance on ALA’s skill and judgment. Uddin had already selected the vehicle’s year, make, and model and had paid a deposit before the later configuration process. The court also considered his experience as a car collector and evidence that he helped identify and correct configuration details.

The court recognized that ALA had expertise about available vehicle options and configurations. But it concluded that ALA did not have the ability to determine or predict whether the vehicle would be considered collectible by the market or by Uddin under his specific definition. The court therefore found no genuine factual dispute on this issue that could prevent summary judgment.

Disposition

The court granted ALA and Boardwalk’s motion for summary judgment. It entered judgment in their favor and against Uddin. Because the court found that Uddin had no viable implied-warranty claim, it did not decide the parties’ dispute over damages.