Garcia v. Harley-Davidson Motor Company, Inc.

CourtDistrict Court, N.D. California
DecidedNovember 15, 2019
Docket3:19-cv-02054
StatusUnknown

This text of Garcia v. Harley-Davidson Motor Company, Inc. (Garcia v. Harley-Davidson Motor Company, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Garcia v. Harley-Davidson Motor Company, Inc., (N.D. Cal. 2019).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 RONALD GARCIA, Case No. 19-cv-02054-JCS

8 Plaintiff, ORDER REGARDING MOTION TO 9 v. DISMISS FIRST AMENDED COMPLAINT 10 HARLEY-DAVIDSON MOTOR COMPANY, INC., et al., Re: Dkt. No. 41 11 Defendants.

12 13 I. INTRODUCTION 14 In this putative class action, Plaintiff Ronald Garcia alleges that several models of 15 motorcycles sold by Defendant Harley-Davidson Motor Company, Inc. (“Harley-Davidson”) 16 included a defective antilock braking system (“ABS”) prone to premature failure during normal 17 operation of the motorcycle. Harley-Davidson moves to dismiss Garcia’s first amended complaint 18 under Rule 12(b)(6) of the Federal Rules of Civil Procedure. The Court hearing on November 15, 19 2019. For the reasons discussed below, the motion is GRANTED in part and DENIED in part. 20 Garcia may file a second amended complaint no later than December 6, 2019.1 21 II. ALLEGATIONS OF THE COMPLAINT 22 Plaintiff Ronald Garcia purchased a new 2008 Harley-Davidson Street Glide motorcycle 23 equipped with ABS from a dealer in Oakland, California in 2008, and paid a premium as 24 compared to motorcycles without ABS. 1st Am. Compl. (“FAC,” dkt. 19) ¶¶ 4, 26, 58, 77.2 25

26 1 The parties have consented to the jurisdiction of the undersigned magistrate judge for all purposed pursuant to 28 U.S.C. § 636(c). 27 2 Because the allegations of the complaint are taken as true on a motion under Rule 12(b)(6), this 1 Harley-Davidson represented in promotional materials that the ABS feature performed effectively 2 and increased emergency braking performance. Id. ¶¶ 27–31. Unbeknownst to Garcia, Harley- 3 Davidson was aware at that time of internal tests showing that normal operation of the 4 motorcycle—specifically, turning the front wheel back and forth—would cause a wire necessary 5 to the ABS system to break well before the expected useful life of the product. See id. ¶¶ 3, 35– 6 37. If the wire broke, the ABS would not function, and while the motorcycles were equipped with 7 a warning light to indicate issues with the ABS, Garcia alleges that the light would not work to 8 reveal this issue. Id. ¶¶ 38–39. 9 Although the motorcycle’s basic “foundation” brakes would continue to function if the 10 ABS failed, Garcia alleges that the undetectable failure of the ABS would nevertheless pose a 11 danger to riders, because Harley-Davidson recommended different methods of using the brakes for 12 motorcycles with or without ABS. Id. ¶¶ 32–34, 38, 40. On motorcycles without ABS, riders 13 were instructed to manually release and reapply the brakes to prevent the wheels from locking and 14 the motorcycle from skidding out, which Harley-Davidson stated “could result in death or serious 15 injury.” Id. ¶ 33. For motorcycles equipped with ABS, Harley-Davidson instructed riders “not 16 [to] modulate or ‘pump’ the brake controls,” but instead to “apply consistent pressure” in order to 17 allow the ABS to automatically control the rate of braking. Id. ¶ 32 (emphasis added). Garcia 18 alleges that a rider who followed those instructions unaware that the ABS had failed could lose 19 control and be killed or injured. Id. ¶ 40. 20 Although Harley-Davidson was aware of this issue with the ABS wiring harness in 2008 21 and began working to change the design, it did not inform owners of the affected motorcycles, and 22 continued to use the same wiring harness in several motorcycle models for the 2008, 2009, and 23 2010 model years, only replacing the wiring harness for the 2011 model years. Id. ¶¶ 42–46. 24 In 2016, the National Highway Traffic Safety Administration (“NHTSA”) investigated a 25 separate ABS issue affecting certain Harley-Davidson motorcycles, including the motorcycles at 26 issue in this case. Id. ¶ 49. That issue related to hydraulic fluid, not wiring, and could cause the 27 brake lever to feel hard and become difficult or impossible to operate. Id. ¶¶ 49–50. Harley- 1 purported wiring harness defect at issue in this case, and Harley-Davidson did not make the public 2 aware of the wiring harness issue. Id. ¶¶ 52–53. Garcia alleges that ABS failures on the Harley- 3 Davidson motorcycles have led to crashes and serious injury, and that Harley-Davidson has 4 received complaints about ABS failures, but his complaint does not make clear whether those 5 failures were caused by the hydraulic fluid issue addressed in the NHTSA investigation or by the 6 wiring issue that is the subject of this case. Id. ¶¶ 41, 47.3 7 Garcia learned of the defect in March of 2019 when information about it was released for 8 the first time on the internet. Id. ¶¶ 62, 64, 67. Garcia’s motorcycle has not overtly indicated that 9 the ABS system has failed, but he has observed “braking characteristics that were inconsistent 10 with other ABS-equipped motorcycles he has ridden.” Id. ¶ 60. He is now “leery of [his] 11 motorcycle and unable to rely on it in an emergency braking situation.” Id. There is no indication 12 in the complaint that Garcia has had his motorcycle inspected by a mechanic to determine whether 13 the ABS is functioning or that he has sought to have it repaired. 14 Garcia asserts the following claims, for which he seeks to represent a class of California 15 purchasers: (1) unlawful, unfair, and fraudulent business practices, in violation of California’s 16 Unfair Competition Law (the “UCL”), FAC ¶¶ 69–87; (2) breach of express warranty under 17 section 2313 of the California Commercial Code, FAC ¶¶ 88–96; (3) breach of implied warranty 18 under section 2314 of the California Commercial Code, FAC ¶¶ 97–103; and (4) breach of implied 19 warranty in violation of California’s Song-Beverly Act, FAC ¶¶ 104–11. For the following 20 remaining claims, Garcia seeks to represent a nationwide class: (5) violation of the federal 21 Magnuson-Moss Warranty Act, FAC ¶¶ 112–123; (6) unjust enrichment, id. ¶¶ 124–129; and (7) a 22 claim for declaratory judgment, id. ¶¶ 130–38. 23 III. ANALYSIS 24 A. Legal Standard 25 A complaint may be dismissed for failure to state a claim on which relief can be granted 26 under Rule 12(b)(6) of the Federal Rules of Civil Procedure. “The purpose of a motion to dismiss 27 1 under Rule 12(b)(6) is to test the legal sufficiency of the complaint.” N. Star Int’l v. Ariz. Corp. 2 Comm’n, 720 F.2d 578, 581 (9th Cir. 1983). Generally, a claimant’s burden at the pleading stage 3 is relatively light. Rule 8(a) of the Federal Rules of Civil Procedure states that a “pleading which 4 sets forth a claim for relief . . . shall contain . . . a short and plain statement of the claim showing 5 that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a). 6 In ruling on a motion to dismiss under Rule 12(b)(6), the court takes “all allegations of 7 material fact as true and construe[s] them in the light most favorable to the non-moving party.” 8 Parks Sch. of Bus. v. Symington, 51 F.3d 1480, 1484 (9th Cir. 1995). Dismissal may be based on a 9 lack of a cognizable legal theory or on the absence of facts that would support a valid theory. 10 Balistreri v.

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Garcia v. Harley-Davidson Motor Company, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/garcia-v-harley-davidson-motor-company-inc-cand-2019.