Singh v. General Motors, LLC

Background

The order addresses three cases brought against General Motors, LLC. The plaintiffs asserted fraud claims and claims under California’s Unfair Competition Law, including claims under its fraudulent, unlawful, and unfair prongs. The claims concerned General Motors’ marketing of the Bolt and the alleged use of defective batteries.

Court’s Analysis

The court held that the fraud claims, including the claims under the fraudulent prong of the Unfair Competition Law, were not pleaded with the particularity required by Federal Rule of Civil Procedure 9(b). The complaints did not identify specifically which misleading advertisements or statements the plaintiffs saw or relied on. They also did not provide more than general allegations that General Motors knew about defects in the Bolt’s battery.

The court also held that the plaintiffs had not plausibly pleaded claims under the unlawful and unfair prongs of the Unfair Competition Law. The complaints made conclusory assertions that the alleged injuries outweighed the benefits provided to consumers and that General Motors’ use of allegedly defective batteries was unlawful, but they did not provide specific supporting facts.

Disposition

The court stated that, at the hearing, the plaintiffs’ counsel said there were no additional facts available to support the fraud and Unfair Competition Law claims. The court therefore granted General Motors’ motions to dismiss those claims without leave to amend. General Motors was ordered to file an answer to the remaining claims in each case within 14 days.

Judge Vince Chhabria issued the order on February 26, 2024.