Fravel v. BMW of N. Am., L.L.C.

2025 Ohio 249
CourtOhio Court of Appeals
DecidedJanuary 29, 2025
Docket30929
StatusPublished

This text of 2025 Ohio 249 (Fravel v. BMW of N. Am., L.L.C.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fravel v. BMW of N. Am., L.L.C., 2025 Ohio 249 (Ohio Ct. App. 2025).

Opinion

[Cite as Fravel v. BMW of N. Am., L.L.C., 2025-Ohio-249.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF SUMMIT )

JOHN FRAVEL C.A. No. 30929

Appellee

v. APPEAL FROM JUDGMENT ENTERED IN THE BMW OF NORTH AMERICA, LLC COURT OF COMMON PLEAS COUNTY OF SUMMIT, OHIO Appellant CASE No. CV-2019-12-4886

DECISION AND JOURNAL ENTRY

Dated: January 29, 2025

CARR, Presiding Judge.

{¶1} Defendant-Appellant BMW of North America, LLC (“BMW”) appeals the

judgment of the Summit County Court of Common Pleas. This Court affirms.

I.

{¶2} In December 2019, Plaintiff-Appellee John Fravel filed a complaint against BMW

asserting violations of Ohio lemon law, Magnuson-Moss Federal Trade Commission Act, express

warranty, implied warranty of merchantability, implied warranty of fitness for a particular purpose,

implied warranty in tort, and the CSPA. The claims all related to a 2017 BMW X3 that Mr. Fravel

had purchased from BMW of Akron in January 2018.

{¶3} Ultimately, the matter proceeded to a jury trial. Following the presentation of Mr.

Fravel’s case, BMW moved for directed verdict. The trial court granted BMW’s motion in part

and denied it part. BMW renewed its motion at the close of the case. The jury was then instructed

as to the Ohio lemon law, express warranty, implied warranty in tort, and CSPA claims. The jury 2

found in favor of BMW on all the claims aside from the CSPA claim. As to the CSPA claim, the

jury awarded Mr. Fravel $30,000.

{¶4} Thereafter, BMW filed a motion for judgment notwithstanding the verdict

(“JNOV”). Mr. Fravel opposed the motion and BMW filed a reply. The trial court denied the

motion.

{¶5} BMW has appealed, raising a single assignment of error for our review.

II.

ASSIGNMENT OF ERROR

THE TRIAL COURT ERRED BY NOT GRANTING BMW OF NORTH AMERICA LLC’S (“BMW”) DIRECTED VERDICT (“DV”) OR JUDGMENT NOTWITHSTANDING THE VERDICT (“JNOV”) MOTIONS REGARDING THE DERIVATIVE CSPA CLAIM WHICH WAS BASED ON THE EXISTENCE OF A WARRANTABLE DEFECT, WHERE THE JURY FOUND IN BMW’S FAVOR ON THE BREACH OF WARRANTY AND LEMON LAW CLAIMS, AND FOUND THAT THERE WAS NO DEFECT IN THE SUBJECT VEHICLE. GIVEN THE VERDICTS ON THE BREACH OF WARRANTY AND LEMON LAW CLAIMS, PER LESTER V. FCA, 2022-OHIO-1776, THERE WAS NO VIABLE BASIS UPON WHICH TO RECOVER UNDER OHIO’S CONSUMER SALES PRACTICES ACT (“CSPA”).

{¶6} BMW asserts in its assignment of error that the trial court erred in denying its

motions for directed verdict and JNOV. However, while BMW’s stated assignment of error

mentions directed verdict, it has not developed an argument specifically with respect to the denial

of its directed verdict motion. Instead, BMW’s motion focuses almost exclusively on the

implications of the jury’s verdict, which would not come into play at the stage of directed verdict.

Compare Civ.R. 50(A) with Civ.R. 50(B). Accordingly, this Court will limit its discussion to

whether the trial court erred in denying BMW’s motion for JNOV.

{¶7} Civ.R. 50(B)(1) states, in relevant part:

Whether or not a motion to direct a verdict has been made or overruled, a party may serve a motion to have the verdict and any judgment entered thereon set aside and 3

to have judgment entered in accordance with the party’s motion. Such a motion shall be served within twenty-eight days of the entry of judgment or, if the clerk has not completed service of the notice of judgment within the three-day period described in Civ.R. 58(B), within twenty-eight days of the date when the clerk actually completes service.

{¶8} “JNOV is proper if upon viewing the evidence in a light most favorable to the non-

moving party and presuming any doubt to favor the nonmoving party reasonable minds could come

to but one conclusion, that being in favor of the moving party.” Gibson Bros., Inc. v. Oberlin

College, 2022-Ohio-1079, ¶ 21 (9th Dist.), quoting State v. The Jacts Group, LLC, 2020-Ohio-

1173, ¶ 29 (9th Dist.). “As a motion for JNOV is decided as a matter of law, this Court will address

these arguments de novo.” Gibson Bros., Inc. at ¶ 21.

{¶9} The facts detailed below were derived from the trial testimony and other evidence.

{¶10} On January 31, 2018, Mr. Fravel purchased a 2017 BMW X3 from BMW of Akron.

The purchase price was $45,480.76. The vehicle was a loaner vehicle which had 5,406 miles on

it at the time of purchase but was sold as new. The vehicle came with a warranty for 48 months

or 50,000 miles, whichever came first. The vehicle replaced Mr. Fravel’s 1997 BMW.

{¶11} Within the first year, Mr. Fravel began experiencing problems with the vehicle.

When asked to describe the problem with the vehicle, Mr. Fravel indicated that “once in a great

while” as you are coming to a stop, all of a sudden you would feel the car surge forward. Mr.

Fravel indicated that the occurrences varied in intensity with the major ones sometimes pushing

the car through an intersection, despite Mr. Fravel having both feet on the brake. The major

incidents did not stop on their own; to end a major incident, Mr. Fravel would have to put both

feet on the brake, then put the car in neutral and tap the accelerator. All eight incidents happened

while braking and they would only happen sporadically. 4

{¶12} The first major incident occurred in late January 2019. Mr. Fravel was driving his

elderly father home from a doctor’s visit. Mr. Fravel was stopping at a light and preparing to make

a right-hand turn. The vehicle began to surge and, despite Mr. Fravel having both feet on the

brake, the vehicle went through the intersection during a red light.

{¶13} Mr. Fravel reported the problem to the Akron dealership. The vehicle was test

driven multiple times by two different individuals and inspected. No fault codes were identified,

and the dealership was unable to replicate the problem or identify its cause. However, the

dealership told Mr. Fravel to bring the vehicle back if the issue persisted.

{¶14} Jason Zweifel, shop foreman of the Akron dealership testified as to the January

2019 investigation. There was testimony that the pedal has two separate sensors, and the system

expects the voltage from the two sensors to align and agree with one another. If one of the sensors

failed, the vehicle would go into limp mode and store a fault code. Limp mode allows the vehicle

to be operated in a limited manner, such as to pull the vehicle over to the side of the road. If both

sensors failed, the vehicle would not move. Mr. Zweifel did not know of a situation in which a

failure of a pedal sensor would cause the vehicle to accelerate or surge. It would also cause a fault

code to be generated. Mr. Zweifel opined that the pedals would not be visible to a person sitting

in the front passenger seat and would only be visible to someone sitting in the middle back

passenger seat if that person was leaning forward. Mr. Zweifel offered to test drive the vehicle

with Mr. Fravel, but Mr. Fravel declined.

{¶15} Another major occurrence happened in early June 2019. That time, Mr. Fravel’s

wife was in the car in the front passenger seat. Mr. Fravel’s wife indicated that during the incident,

Mr. Fravel’s fingers were clenched around the steering wheel, and he was pushing his foot as hard

as he could on the brake and the car still was lurching forward. Mr. Fravel’s wife indicated that it 5

stopped after Mr. Fravel put the vehicle in neutral. Mr. Fravel’s wife testified that she saw Mr.

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2025 Ohio 249, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fravel-v-bmw-of-n-am-llc-ohioctapp-2025.