Sadeghi-A v. Daimler Trucks North America LLC

Background

Ardalan Sadeghi-A purchased a new 2017 Newmar London Aire motorhome in August 2016. Daimler Trucks North America LLC and Freightliner Custom Chassis Corporation designed and manufactured the motorhome’s chassis and related components, including its passive steer tag axle. The defendants provided an express New Vehicle Limited Warranty covering defects in materials and workmanship under normal use and requiring repair or replacement of defective components. The basic chassis was covered for three years or 50,000 miles, whichever came first.

Sadeghi-A sued in July 2019 and filed an amended complaint in March 2021. He alleged ongoing tag-axle defects and other problems, including electrical issues, pulling to the left, vibration, tire wear, failing lights, leaks, and other motorhome problems. His amended complaint asserted seven causes of action.

Earlier Summary-Judgment Order

The defendants moved for partial summary judgment on Count 7, which sought punitive damages; Counts 5 and 6, which asserted fraud; and Counts 1 through 4, but only to the extent those warranty claims were based on misalignment of the tag axle. On March 14, 2022, the court granted the motion in part and denied it in part. It dismissed Count 7, left Counts 5 and 6 in place, and dismissed Counts 1 through 4 “to the extent that they are based on the allegation that Defendants breached the express Warranty.” The court did not limit that language to the tag-axle defect.

The earlier order primarily distinguished between manufacturing defects, which the warranty covered, and design defects, which it did not. The court determined that the tag-axle defect was a non-covered design defect.

Reconsideration

The court explained that a district court may reconsider and modify an interlocutory order—an order issued before final judgment—before judgment is entered. Reconsideration may correct a clear legal or factual error or address newly discovered evidence, but it is not a vehicle for presenting evidence or arguments that could have been raised earlier.

The court concluded that its earlier ruling on Counts 1 through 4 was too broad. The defendants’ opening brief had focused exclusively on the tag-axle defect and had argued for summary judgment on express-warranty claims involving tag-axle alignment. The court found that the defendants had not submitted sufficient evidence or argument concerning the other alleged defects to show that no genuine factual disputes existed about those claims.

The court also stated that, even if the defendants had addressed the non-tag-axle defects in their initial motion, summary judgment would not have been warranted on the evidence then before the court. For a manufacturing-defect claim, Sadeghi-A had to show that the product departed from its intended design, that the departure existed when the product left the defendants’ control, and that it caused his damages. Viewing the evidence in Sadeghi-A’s favor, the court found sufficient evidence to create factual disputes about those elements. That evidence included an expert report concerning continuing electrical-system problems, Sadeghi-A’s declaration describing repair attempts, and supporting documents. The court also found that Sadeghi-A had not testified that the electrical problems were resolved.

Ruling

Judge Michael J. Davis granted Sadeghi-A’s Motion for Reconsideration. The court amended the March 14, 2022 partial-summary-judgment order so that Counts 1 through 4 are dismissed only to the extent they rely on allegations that the defendants breached the express warranty based on the tag-axle defect. Any additional, non-tag-axle defect allegations related to Counts 1 through 4 were outside the scope of the court’s ruling. The March 14 order remained the same in all other respects. The court noted that Sadeghi-A would still need admissible evidence at trial to support each element of his warranty claims, including properly disclosed expert testimony if required.