Petrosyan v. BMW of North America CA2/4

CourtCalifornia Court of Appeal
DecidedFebruary 27, 2025
DocketB327267
StatusUnpublished

This text of Petrosyan v. BMW of North America CA2/4 (Petrosyan v. BMW of North America CA2/4) 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
Petrosyan v. BMW of North America CA2/4, (Cal. Ct. App. 2025).

Opinion

Filed 2/27/25 Petrosyan v. BMW of North America CA2/4 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(a). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115(a).

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA SECOND APPELLATE DISTRICT DIVISION FOUR

ARAM PETROSYAN, B327267

Plaintiff and Appellant, Los Angeles County Super. Ct. No. v. 22BBCV00467 BMW OF NORTH AMERICA, LLC, et al.,

Defendants and Respondents.

APPEAL from a judgment of the Superior Court of Los Angeles County, John J. Kralik, Judge. Affirmed. The Bravo Law Firm and Nicholas A. Bravo for Plaintiff and Appellant. The Law Office of Abtin Amir and Abtin Amir for Defendant and Respondent BMW of North America, LLC. Manning, Leaver, Bruder & Berberich and Gary Prudian for Defendant and Respondent Finchey Corporation of California. INTRODUCTION

Aram Petrosyan sued BMW North America, LLC (BMW NA) and Finchey Corporation of California, dba Pacific BMW (Pacific BMW). He seeks relief for the defendants’ alleged failure to satisfy their obligations under the Song-Beverly Consumer Warranty Act, Civil Code1 section 1790 et seq. (Song-Beverly Act or the Act), concerning a used BMW convertible in his possession. An authorized BMW dealership originally leased the BMW to a non-party. Less than a year into the lease’s three-year term, however, the non-party lessee assigned his interests under the lease to Petrosyan. BMW NA, joined by Pacific BMW, demurred to Petrosyan’s operative complaint, arguing he lacked standing to sue under the Song-Beverly Act.2 The trial court sustained the demurrer without leave to amend and dismissed the complaint with prejudice. For the reasons discussed below, we affirm.

BACKGROUND

I. Factual Background On review of an order sustaining a demurrer, “[w]e accept as true all properly pleaded material factual allegations of the complaint and other relevant matters that are properly the subject of judicial notice . . . .” (Glen Oaks Estates Homeowners Assn. v. Re/Max Premier Properties, Inc. (2012) 203 Cal.App.4th 913, 919.) Accordingly, the following facts are taken from Petrosyan’s operative complaint or documents the trial court

1 All undesignated statutory references are to the Civil Code. 2 Rather than filing an appellate brief on its own behalf, Pacific BMW joins BMW NA’s respondent’s brief.

2 judicially noticed. (See ibid; see also Evid. Code, § 459, subd. (a) [appellate courts must “take judicial notice of . . . each matter properly noticed by the trial court”].) BMW NA manufactures, sells, warrants, and distributes BMW vehicles. Pacific BMW sells, leases, and repairs BMW vehicles. In February 2020, non-party Gamer Aleksanian leased a new 2019 BMW convertible from BMW/Mini of Monrovia, another authorized BMW dealership, for a three-year term. The lease stated that, as a new car, the convertible was “subject to the standard manufacturer’s new vehicle warranty.” Upon acceptance of the lease’s terms, BMW/Mini of Monrovia assigned its interests in the convertible and the lease to BMW Financial Services NA, LLC (BMW FS), a wholly owned subsidiary of BMW NA. The lease barred Aleksanian from assigning the lease or his rights thereunder without prior written approval from BMW/Mini of Monrovia or BMW FS. Subsequently, Aleksanian assigned his interests in the lease to Petrosyan by way of a Lease Transfer Agreement. Signed by Petrosyan and Aleksanian in July and September 2020, respectively, the Lease Transfer Agreement identifies Aleksanian as the transferor and original lessee, and identifies Petrosyan as the transferee and new lessee. BMW FS consented to the Lease Transfer Agreement in October 2020. Per the agreement, Aleksanian was “relieve[d] . . . from [his] obligations under the [l]ease.” Petrosyan, in turn, “accept[ed] all the rights, interest [sic] and obligations of [Aleksanian] as set forth in the [l]ease, including but not limited to, making payments as they become due . . . .” When Aleksanian executed the Lease Transfer Agreement, the vehicle had 10,427 miles on its odometer.

3 Petrosyan alleges that when he acquired the convertible, he “received written warranties and other express and implied warranties including, but not limited to, warranties from [BMW NA] and [Pacific BMW] that the [v]ehicle and its components would be free from all defects in material and workmanship; that the [v]ehicle would pass without objection in the trade under the contract description; that the [v]ehicle would be fit for the ordinary purposes for which it was intended; that the [v]ehicle would conform to the promises and affirmations of fact made; that [the] [d]efendants, and each of them, would perform any repairs, alignments, adjustments, and/or replacements of any parts necessary to ensure that the [v]ehicle was free from any defects in material and workmanship; that [the] [d]efendants, and each of them, would maintain the utility of the [v]ehicle for 4 years/50,000 miles and 4 years/50,000 miles for powertrain[ ] [and] restraint defects, and would conform the [v]ehicle to the applicable express warranties.” Since taking possession of the convertible, Petrosyan “has presented the vehicle on multiple occasions for warrantable non- conformities/defects, such as the [v]ehicle making unusual noises while driving, vibrate [sic] while driving, and/or leak [sic], and/or glass to pop out of place [sic], and/or illuminate [sic] check-engine lights substantially affecting the use, value and safety of the vehicle.”

II. Procedural Background Seeking relief under the Song-Beverly Act, the operative first amended complaint asserts the following causes of action: (1) breach of implied warranty of merchantability (against BMW NA); (2) breach of express warranty of merchantability (against

4 BMW NA); and (3) violation of section 1793.2, subdivision (b) (against both defendants). BMW NA demurred to each cause of action on the ground that Petrosyan failed to allege sufficient facts to constitute a cognizable cause of action. In support of its position, BMW NA primarily3 argued Petrosyan “lacks standing to pursue any claims under [the] Song-Beverly [Act] because he obtained the vehicle used via a private transfer from a private individual, and did not purchase it new from a qualifying retail seller.” It also noted “[n]o new warranty was issued to [Petrosyan] at the time of sale.” Although it previously filed an answer to the initial complaint, Pacific BMW joined BMW NA’s demurrer. It agreed entirely with BMW NA’s arguments and did not present any contentions on its own behalf.

3 Concerning Petrosyan’s first cause of action, BMW NA also argued that he failed to allege sufficient facts to constitute a cognizable cause of action because “BMW NA is a distributor as defined by the Act specifically with regard to implied warranties of merchantability, which applies only to retail sellers and manufacturers, and therefore BMW NA cannot be held liable for the retail seller or manufacturer’s implied warranty created by operation of law only as to those entities.” Regarding Petrosyan’s third cause of action, BMW NA argued its demurrer should be sustained because he “fail[ed] to allege that any one presentation for repair took longer than 30 days, or that any such delay was not caused by conditions beyond the control of BMW NA or its representatives, such as the COVID-19 [sic] and the global supply chain shortage experienced by all auto companies over the last few years.” The trial court rejected both of these arguments and BMW NA has not renewed either one on appeal. We therefore deem these arguments forfeited. (Tiernan v. Trustees of Cal.

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Petrosyan v. BMW of North America CA2/4, Counsel Stack Legal Research, https://law.counselstack.com/opinion/petrosyan-v-bmw-of-north-america-ca24-calctapp-2025.