Cummins, Inc. v. Superior Court

115 P.3d 98, 30 Cal. Rptr. 3d 823, 36 Cal. 4th 478, 2005 Daily Journal DAR 8551, 2005 Cal. Daily Op. Serv. 6264, 2005 Cal. LEXIS 7605
CourtCalifornia Supreme Court
DecidedJuly 18, 2005
DocketS117726
StatusPublished
Cited by74 cases

This text of 115 P.3d 98 (Cummins, Inc. v. Superior Court) is published on Counsel Stack Legal Research, covering California Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cummins, Inc. v. Superior Court, 115 P.3d 98, 30 Cal. Rptr. 3d 823, 36 Cal. 4th 478, 2005 Daily Journal DAR 8551, 2005 Cal. Daily Op. Serv. 6264, 2005 Cal. LEXIS 7605 (Cal. 2005).

Opinion

Opinion

GEORGE, C. J.

The Song-Beverly Consumer Warranty Act (hereafter sometimes referred to as the Act), Civil Code section 1791 et seq., 1 provides that if a manufacturer or its representative in this state fails to repair a new motor vehicle to conform to any express warranty after a reasonable number of attempts to repair, the manufacturer must replace the vehicle or pay restitution. (§ 1793.2, subd. (d)(2).) The question presented in this case is whether a buyer who resides in California may bring suit against a manufacturer under the Act when the buyer purchased the vehicle in another state, but brought the vehicle for repair to the manufacturer’s authorized repair facility in California, and repeated attempts to repair the vehicle proved unsuccessful. We conclude that the Act does not apply unless the vehicle was purchased in California.

I.

During a visit to Idaho, plaintiffs Edward and Saudi Cox, who are California residents, purchased a motor home manufactured by defendant Winnebago Industries, Inc. and equipped with an engine made by defendant Cummins, Inc. 2 Plaintiffs filed a complaint in the Riverside County Superior Court against defendants, alleging that the motor home did not conform to express warranties and that its engine was defectively manufactured. The first cause of action was a claim for breach of express warranty and violation of the Act. Plaintiffs alleged that their vehicle was defective in numerous ways. The complaint alleged that the manufacturers’ authorized repair facilities in Riverside County, California, had failed to remedy these defects after numerous attempts, and that the manufacturers violated the Act by not replacing the vehicle or providing a refund. The complaint sought actual damages of $285,872.80 plus attorney fees and a civil penalty of up to twice the amount of actual damages, the remedies provided in section 1794, subdivision (e)(1). *484 The complaint also alleged other claims, including a violation of the federal “lemon law,” the Magnuson-Moss Consumer Warranty Act. (15 U.S.C. § 2301 et seq.)

Defendants moved for summary adjudication of the first cause of action on the ground that plaintiffs had purchased the motor home in Idaho, arguing that the Act applies only to vehicles purchased in California. In opposing the motion, plaintiffs argued that the California statute applies if the manufacturer’s representative in California— that is, the authorized repair facility—fails after a reasonable number of attempts to repair the vehicle to conform to the express warranty. The trial court denied the motion for summary adjudication. Defendants filed a petition for writ of mandate in the Court of Appeal. That court issued an alternative writ, but after briefing and argument denied the writ, concluding that the Act applies whenever a manufacturer that sells goods in California (or its representative) “fails to service or repair the good to conform to its express warranty, even in cases when the particular good was purchased out of state.” We granted review.

II.

The Song-Beverly Consumer Warranty Act was enacted to address the difficulties faced by consumers in enforcing express warranties. Consumers frequently were frustrated by the inconvenience of having to return goods to the manufacturer for repairs and by repeated unsuccessful attempts to remedy the problem. (See Comment, Toward an End to Consumer Frustration Making the Song-Beverly Consumer Warranty Act Work (1974) 14 Santa Clara L.Rev. 575, 580.) The Act protects purchasers of consumer goods by requiring specified implied warranties, placing strict limitations on how and when a manufacturer may disclaim those implied warranties, and providing mechanisms to ensure that manufacturers live up to the terms of any express warranty. (See §§ 1792-1792.5, 1793, 1793.2.)

Among other provisions, the Act requires manufacturers of consumer goods sold in California to make available to buyers service and repair facilities at which goods can be repaired to conform to any express warranties provided by the manufacturer. “Every manufacturer of consumer goods sold in this state and for which the manufacturer has made an express warranty” must “[mjaintain in this state sufficient service and repair facilities” to carry out the terms of the express warranty. (§ 1793.2, subd. (a)(1)(A).) The *485 manufacturer may maintain its own repair facility or may designate and authorize an independent repair facility to meet its responsibilities under its express warranties. (§ 1793.2, subd. (a)(1)(B).)

In addition, the Act specifies time frames within which repairs under an express warranty must be provided. Service and repair at the manufacturer’s authorized repair facility in the state must be commenced “within a reasonable time.” (§ 1793.2, subd. (b).) Goods must be repaired to comply with the warranty within 30 days, unless delay is caused by conditions beyond the control of the manufacturer or its representative. (Ibid.)

In those instances when the goods cannot be repaired to conform to an express warranty after a “reasonable number of attempts,” the Act specifies a remedy, in what has been referred to as the “refund-or-replace” provisions. (§ 1793.2, subd. (d)(1) & (2); see Kwan v. Mercedes-Benz of North America, Inc. (1994) 23 Cal.App.4th 174 [28 Cal.Rptr.2d 371].) For consumer goods generally, the manufacturer must either replace the goods or reimburse the buyer in an amount equal to the purchase price, less a reasonable amount for the buyer’s use of the goods during the period preceding detection of the nonconformity. (§ 1793.2, subd. (d)(1).) A buyer who “is damaged by a failure to comply with any obligation” under the Act may bring an action for damages and other relief. (§ 1794, subd. (a).)

The Legislature has amended the Act and adopted additional provisions that address the special problems experienced by consumers in enforcing warranties on new motor vehicles. (See Stats. 1982, ch. 388, § 1, p. 1720; Stats. 1987, ch. 1280, § 2, p. 4557; Stats. 1992, ch. 1232, § 6, p. 5788; Stats. 1999, ch. 448.) These provisions frequently are referred to as the lemon law. In any case involving a new motor vehicle, there is a rebuttable presumption that a reasonable number of attempts have been made to repair the vehicle if, within 18 months or 18,000 miles, whichever comes first, either (1) the same problem has been subject to repair four or more times (or, if the problem is likely to cause death or serious bodily injury, two or more times) and the buyer has notified the manufacturer directly of the need for the repair, or (2) the vehicle is out of service for more than 30 calendar days because of repair under the warranty. (§ 1793.22, subd. (b).) If the buyer prevails in an action involving a new motor vehicle, the buyer may recover damages and reasonable attorney fees and costs and, under some circumstances, a “civil penalty of up to two times the amount of damages.” (§ 1794, subd. (e)(1).) The lemon law also provides manufacturers with the option of establishing a third party dispute resolution process to address disputes over the enforcement of express *486

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115 P.3d 98, 30 Cal. Rptr. 3d 823, 36 Cal. 4th 478, 2005 Daily Journal DAR 8551, 2005 Cal. Daily Op. Serv. 6264, 2005 Cal. LEXIS 7605, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cummins-inc-v-superior-court-cal-2005.