Hardy v. Forest River, Inc.

CourtCalifornia Court of Appeal
DecidedJanuary 31, 2025
DocketB331450
StatusPublished

This text of Hardy v. Forest River, Inc. (Hardy v. Forest River, Inc.) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hardy v. Forest River, Inc., (Cal. Ct. App. 2025).

Opinion

Filed 1/9/25; Modified and Certified for Pub. 1/31/25 (order attached)

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION TWO

JEAN M. HARDY, B331450

Plaintiff and Appellant, (Los Angeles County Super. Ct. No. 22NWCV01656) v.

FOREST RIVER, INC., et al.,

Defendants and Respondents.

APPEAL from an order of the Superior Court of Los Angeles County, Lee W. Tsao, Judge. Reversed and remanded. Lawrence J. Hutchens and Shay Dinata-Hanson for Plaintiff and Appellant. Phillips, Spallas & Angstadt, Michael R. Halvorsen and Matthew A. Gardner for Defendants and Respondents.

_________________________ A California consumer enters into an agreement with an RV manufacturer that all legal disputes regarding the sale will be resolved in Indiana, governed by Indiana law. Upon the consumer’s filing of a lawsuit in California under the Song- Beverly Consumer Warranty Act (Song-Beverly Act) (Civ. Code, § 1790 et seq.), the RV manufacturer files a motion to stay or dismiss the action on forum non conveniens grounds, contending that the exclusive jurisdiction for this case is Indiana. The manufacturer further argues that to “allay” any concerns that plaintiff’s “essentially unwaivable” rights under the Song-Beverly Act will be forfeited if the case is resolved in Indiana, it will stipulate that California law will apply to plaintiff’s warranty claims and will not oppose a request that the Indiana court “use Song-Beverly to adjudicate those allegations.” This case raises the question whether, in the face of an unconscionable agreement, a trial court may correct the problem by staying the action so that, “should the Indiana court decline to apply the Song-Beverly Act, then plaintiff can move to lift the stay on this matter.” We conclude that the lower court erred in its application of the legal standard and in its conclusion that a stipulation to apply California law and concomitant stay of the action would remedy the waiver of non-waivable rights. For these reasons, we reverse and remand. FACTUAL AND PROCEDURAL BACKGROUND Jean Hardy filed a complaint for damages against Forest River, Inc. and related defendants (Forest River) on December 19, 2022. The complaint alleged a single cause of action under the Song-Beverly Act. Hardy alleged that she purchased a

2 motorhome 1 at the retail price of $130,543.61, but that Forest River and its authorized repair facilities failed to either perform all necessary repairs to correct its defects or replace it, thereby breaching the express and implied warranties of merchantability. Forest River then filed a motion to stay or dismiss the action on the ground of forum non conveniens, contending that exclusive jurisdiction for the case was in the state of Indiana. Specifically, Forest River contended that in the Limited Motorized Warranty applicable to this sale, there was a forum selection clause that advised purchasers, in all caps, that “exclusive jurisdiction for deciding legal disputes relating to the limited warranty, an alleged breach of warranty, breach of implied warranties, or representations of any kind must be filed within the state of Indiana.” In its motion, Forest River initially cited the wrong standard for ruling on a forum selection clause, using the general standard rather than the standard that applies when the claims at issue are based on unwaivable rights created by California statutes. However, it conceded later in its brief that “Plaintiff may fear she could lose rights she might have asserted under Song-Beverly if the forum selection clause in Forest River’s Limited Warranty is enforced.” Forest River recognized that “the California Legislature made, with certain exceptions, a buyer’s rights under Song-Beverly essentially unwaivable. [Citation.] Therefore, to allay any concerns in that regard, Forest River will stipulate by this motion that Song-Beverly will apply to plaintiff’s warranty claims pursued in an action in

1 We use the term “motorhome” and “RV” interchangeably, as do the parties.

3 Indiana and that it will not oppose a request that the Indiana court use Song-Beverly to adjudicate those allegations.” Prior to a hearing on the motion, the trial court granted a motion for trial preference under Code of Civil Procedure section 36, subdivision (e). Hardy opposed the motion to stay the action, pointing out that the correct standard for ruling on such a motion in the context of a case involving unwaivable rights created by California statutes placed the burden of proof on the defendant, not the plaintiff. Hardy also argued that the warranty contained unfair and unconscionable provisions that violated California law. In addition to the forum selection and choice of law provisions, which were in the document shown to plaintiff, Hardy claimed there were additional unconscionable provisions in the warranty and that it was not shown to her until after she had signed the sales documents and taken possession of the motorhome. Specifically, Hardy argued that the warranty contained a 90-day statute of limitations (in contrast to four years under California law); required the consumer to deliver the RV to Forest River in Indiana for service if repairs are not adequately completed by the seller or local authorized dealer; required an exhaustion of remedies prior to bringing suit which was more onerous than that required by the Song-Beverly Act; and contained a disclaimer from incidental or consequential damages inconsistent with the Song-Beverly Act. Finally, plaintiff argued that Forest River’s offer to stipulate to apply California law did not cure the unenforceability of the choice of law and forum selection clause. Both in her

4 opposition and at oral argument, Hardy’s counsel stated that she did not accept the stipulation. In reply, Forest River again cited to cases holding that the plaintiff had the burden to show the forum selection clause to be unenforceable and argued that Hardy had not met her burden here. Forest River also argued that even if, arguendo, “certain provisions of the limited warranty might be unenforceable, plaintiff ma[de] no showing that those provisions cannot be severed from the limited warranty—including the mandatory forum selection clause.” The trial court granted the motion. In the section addressing the legal standard, the court followed Forest River’s lead in stating the general rule that places “a substantial burden on a plaintiff seeking to defeat” a forum selection clause, requiring the plaintiff to demonstrate that the “forum selected would be unavailable or unable to accomplish substantial justice” and placing the burden of proof on the party opposing the enforcement of the clause. However, in the section entitled “Enforceability,” the trial court correctly noted that the “burden is reversed when the claims at issue are based on unwaivable rights created by California statutes.” The trial court concluded that Forest River had met its burden “because Plaintiff signed the forum selection clause, the forum selection clause is not unconscionable, and Plaintiff’s Song- Beverly rights can be readily preserved.” Responding to Hardy’s contention that the warranty clause was “unconscionable because Plaintiff was not given a copy of the limited warranty to review prior to signing and agreeing to the limited warranty,” the court concluded that she “did sign a separate page with only the forum selection clause.” Finally, the court concluded that Hardy’s

5 concern about whether California law will be applied in Indiana could “be remedied by staying this matter while the Indiana case is pending and should the Indiana court decline to apply the Song-Beverly Act, then Plaintiff can move to lift the stay on this matter.” This appeal followed. DISCUSSION I.

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Hardy v. Forest River, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/hardy-v-forest-river-inc-calctapp-2025.