Minocha v. Mercedes-Benz, USA LLC

Background

Atul Minocha bought a 2021 Mercedes-Benz G550 Wagon Truck from Mercedes-Benz of San Francisco on January 31, 2021, for $178,793.75. The vehicle was delivered on February 15. A few days later, its check-engine light came on. Minocha brought the vehicle to Mercedes-Benz of Reno five more times for the same problem, and the vehicle spent more than 60 days at the shop.

Minocha alleged that Mercedes-Benz supplied written warranties, including a four-year, 50,000-mile basic warranty. He asserted claims for breach of express and implied warranty under the federal Magnuson-Moss Warranty Act and a claim under Nevada’s Lemon Law. His complaint sought, among other remedies, a replacement vehicle.

The parties disputed what happened after Minocha contacted Mercedes-Benz. Minocha said he requested a replacement vehicle. Mercedes-Benz later internally recorded that it agreed to repurchase or replace the vehicle and sent Minocha a letter stating that it agreed to repurchase and that a transfer agent would prepare a repurchase offer. Minocha never received a repurchase offer. Communications also indicated that Mercedes-Benz viewed a buyback as his only option, while Minocha maintained that he could choose between a replacement and cash value.

Nevada Lemon Law Interpretation

Nevada Revised Statutes § 597.630 requires a manufacturer that cannot conform a vehicle to an applicable express warranty after a reasonable number of repair attempts to either replace the vehicle with a comparable vehicle or accept its return and refund the purchase price, subject to a reasonable allowance for the buyer’s use.

The court found the statute ambiguous about who chooses between replacement and repurchase. It adopted the interpretation that the manufacturer must replace the vehicle or, if the buyer agrees, repurchase it. The court reasoned that this interpretation better served the statute’s purpose of protecting consumers and encouraging manufacturers to produce nondefective vehicles. The court also relied on another Nevada Lemon Law provision referring to a buyer’s claim for replacement or refund, concluding that it would not make sense for the buyer to choose during an informal dispute process but for the manufacturer to choose in court.

Because Mercedes-Benz’s argument depended on the manufacturer having the right to choose repurchase instead of replacement, the court rejected summary judgment on that legal theory.

Disputed Facts

The court separately found genuine disputes of material fact, meaning factual conflicts that a reasonable jury could resolve either way. A jury could find that Mercedes-Benz said it intended to make a repurchase offer but never actually made one. A jury could also find that Minocha requested a replacement and did not offer to return the vehicle or agree to repurchase.

Those disputes created an issue for trial about whether Mercedes-Benz complied with the Nevada requirement to replace the vehicle or accept its return and provide a refund.

Magnuson-Moss Argument Raised in Reply

Mercedes-Benz raised a separate argument in its reply brief concerning the structure of the Magnuson-Moss Warranty Act. It argued that it was entitled to judgment because it could not provide a replacement and repair was not commercially practicable or could not be completed on time. The court declined to consider that argument or the related reply evidence because Mercedes-Benz raised it for the first time in its reply.

Disposition

Judge Jacquelyn Corley denied Mercedes-Benz’s motion for summary judgment. The order states that Mercedes-Benz was not entitled to summary judgment on the Nevada Lemon Law or Magnuson-Moss claims and that the order disposed of Docket No. 41.