Meeks v. FCA US LLC

CourtDistrict Court, E.D. California
DecidedOctober 7, 2024
Docket1:22-cv-00761
StatusUnknown

This text of Meeks v. FCA US LLC (Meeks v. FCA US LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Meeks v. FCA US LLC, (E.D. Cal. 2024).

Opinion

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6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10

11 CARL MEEKS, ) Case No.: 1:22-cv-0761 JLT CDB ) 12 Plaintiff, ) ORDER GRANTING IN PART PLAINTIFF’S ) MOTION FOR ATTORNEY FEES, COSTS, AND 13 v. ) EXPENSES ) (Doc. 59) 14 FCA US LLC, et al., ) ) ORDER TERMINATING THE BILL OF COSTS 15 Defendants. ) AS MOOT ) (Doc. 58) 16

17 Carl Meeks asserted that his Dodge Ram 1500—which was manufactured and/or distributed by 18 FCA US LLC—was defective and required multiple repairs. He sought to hold FCA liable for 19 violations of the Song-Beverly Consumer Warrant Act and breach of the implied warranty of 20 merchantability. (Doc. 1.) The parties settled the underlying claims, and Meeks now seeks an award of 21 attorney fees and costs. (Doc. 59.) For the reasons set forth below, the motion is GRANTED in part, 22 in the modified amount of $19,364.50. 23 I. Background and Allegations 24 Meeks alleges that he purchased a 2019 Dodge Ram 1500 “primarily for family or household 25 purposes.” (Doc. 1 at 3, ¶ 11.) He contends that he “entered into a warranty contract with Defendant 26 FCA” regarding his Dodge Ram, “which was manufactured and/or distributed by Defendant FCA.” 27 (Id. ¶ 9.) Meeks asserts, “The warranty contract contained various warranties, including but not limited 28 to the bumper-bumper warranty, powertrain warranty, [and] emission warranty.” (Id., ¶ 10.) 1 According to Meeks, “Defects and nonconformities to warranty manifested themselves within 2 the applicable express warranty period, including but not limited to, the electrical system, the engine, 3 [and] the transmission, among other defects and non-conformities.” (Doc. 1 at 4, ¶ 14.) Meeks 4 “presented the Vehicle” for service and repairs several times between 2019 and 2021. (Id. at 9, ¶ 44; 5 see also Doc. 59-2 at 3-4, ¶¶ 6-14.) 6 Meeks first presented the truck for repairs due to “issues with the seats” with 1,000 miles on the 7 odometer, on May 19, 2019, and the dealer returned the truck to Meeks on the same day. (Doc. 59-2 at 8 3, ¶ 6.) He next took his Dodge Ram for repairs on June 19, 2019, reporting “the driver seat upper 9 cushion on the inner side” was uncomfortable, the truck shook when starting up, and was “rumbling 10 when coming to a stop.” (Id., ¶ 7.) He received the truck two days later. (Id.) On July 11, 2019, 11 Meeks called FCA’s “Proactive ECS Outbound Program reporting that there was a rattle in the truck 12 and that it misfired.” (Id., ¶ 8.) The following month, Meeks took the truck to an authorized dealership 13 “reporting the vehicle seems to misfire, shook, and loses power.” (Id., ¶ 9.) 14 In 2020, Meeks continued to report issues with his Dodge Ram truck and sought additional 15 repairs. (Doc. 59-2 at 3-4, ¶¶ 10-13.) On June 11, 2020, with 21,000 miles on the truck’s odometer, 16 Meeks informed an authorized representative that his truck rumbled, was “not sparking properly,” and 17 got stuck in first gear. (Id., ¶ 10.) The following month, Meeks took his truck to FCA’s authorized 18 repair facility, reporting the truck cab shook with no power, made “a whomping noise,” and “would 19 not shift out of first” on three occasions. (Id. at 4, ¶ 11.) A “repair technician performed a TCM flash 20 update,” and returned the truck to Meeks on the same day. (Id.) In September 2020, “with 25,253 21 miles on the odometer,” Plaintiff returned the truck to a repair facility, reporting “the check engine 22 light was on,” the truck was losing power, and the cab was shaking. (Id., ¶ 12.) A “technician 23 removed cylinder 3 ignition coil and spark plugs and found misfire,” and performed repairs “under 24 warranty.” (Id.) The facility returned the truck to Meeks two days later. (Id.) 25 Meeks presented his truck for repairs for the sixth, and final, time on April 14, 2021. (Doc. 59- 26 2 at 4, ¶ 14.) At that time, Meeks reported “the engine shakes and loses power and has gotten stuck in 27 first gear, and that the vehicle smells of coolant.” (Id.) The authorized repair facility “was unable to 28 verify the engine issue.” (Id.) Meeks’ truck was returned to him eight days later. (Id.) 1 On July 26, 2021, Meeks filed a complaint in Los Angeles Superior Court against FCA, 2 alleging violations of the Song-Beverly Act. (Doc. 59-2 at 5, ¶ 15.) However, Meeks later filed a 3 request for dismissal of the entire complaint from the state court. (Id. at 6, ¶ 27.) 4 On June 22, 2022, Meeks initiated this action in the district court, asserting this Court has 5 diversity jurisdiction pursuant to 28 U.S.C § 1332. (Doc. 1 at 2.) Meeks seeking to hold FCA liable 6 for violations of the Song-Beverly Act—including Cal. Civ. Code §§ 1793.2(d), 1793.2(b), and 7 1793.2(a)(3)—and breach of the implied warranty of merchantability. (See Doc. 1 at 8-11.) Meeks’ 8 prayer for relief included, but was not limited to: general, special, actual, consequential, and incidental 9 damages; “reimbursement and/or restitution of all monies expended;” diminution in value; civil 10 penalties totaling twice the actual damages; and “reasonable attorneys’ fees.” (Id. at 12.) 11 Meeks notified the Court that he “accepted Defendant FCA US LLC’s Offer of Judgment 12 Pursuant to Fed. R. Civ. P. 68 in the amount of $137,384.88.” (Doc. 48 at 2.) The Court entered 13 judgment and closed the case on December 14, 2023. (Docs. 49, 50.) Pursuant to the terms of the 14 executed “Offer of Judgment,” the parties agreed that if they were “unable to resolve attorney’s fees 15 and costs, Plaintiff[] may seek reasonable costs, expenses and attorneys’ fees pursuant to a properly 16 noticed motion…” (Doc. 48 at 5, ¶ 3.) 17 The parties also stipulated to two extensions of time to file a motion for attorneys’ fees and 18 costs, which the Court approved. (Docs. 52, 53, 54, 55.) However, the Court denied the third request 19 on May 8, 2024, noting the parties did not provide “any explanation as to why they have been able to 20 meet and confer in the five months since the Court entered judgment.” (Doc. 57 at 1.) Meeks filed a 21 Bill of Costs on May 29, 2024, and the pending motion for attorneys’ fees and costs on May 30, 2024. 22 (Docs. 58, 59.) The Court ordered FCA to file any opposition no later than September 13, 2024, and 23 warned FCA the failure to do so would result in the motion being deemed unopposed. (Doc. 62.) FCA 24 did not file any opposition, and the time to do has expired. 25 II. Awards for Fees, Costs, and Expenses 26 “In a diversity case, the law of the state in which the district court sits determines whether a 27 party is entitled to attorney fees, and the procedure for requesting an award of attorney fees is 28 governed by federal law.” Carnes v. Zamani, 488 F.3d 1057, 1059 (9th Cir. 2007); see also Mangold 1 v. Cal. Public Utilities Comm’n, 67 F.3d 1470, 1478 (9th Cir. 1995) (noting that in a diversity action, 2 the Ninth Circuit “applied state law in determining not only the right to fees, but also in the method of 3 calculating the fees”). 4 As explained by the Supreme Court, “[u]nder the American Rule, ‘the prevailing litigant 5 ordinarily is not entitled to collect a reasonable attorneys’ fee from the loser.’” Travelers Casualty & 6 Surety Co. of Am. v. Pacific Gas & Electric Co., 549 U.S. 443, 448 (2007) (quoting Alyeska Pipeline 7 Service Co. v. Wilderness Society, 421 U.S. 240, 247 (1975)).

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Meeks v. FCA US LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/meeks-v-fca-us-llc-caed-2024.