Siqueiros v. General Motors LLC

District Court, N.D. California·Decided August 29, 2022·No. 3:16-cv-07244·Unknown

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 RAUL SIQUEIROS, et al., Case No. 16-cv-07244-EMC

8 Plaintiffs, ORDER GRANTING PLAINTIFFS’ 9 v. MOTION FOR DETERMINATION OF GARET TARVIN’S ADEQUACY TO 10 GENERAL MOTORS LLC, SERVE AS CALIFORNIA CLASS REPRESENTATIVE, AND GRANTING 11 Defendant. IN PART AND DENYING IN PART GENERAL MOTORS’ MOTION FOR 12 SUMMARY JUDGMENT ON TARVIN’S CLAIMS 13 Docket Nos. 413, 428 14 15 16 I. INTRODUCTION 17 Plaintiffs allege that Defendant General Motors LLC (“GM” or “Defendant”) knowingly 18 manufactured and sold a car engine with inherent defects that caused excessive oil consumption 19 and engine damage. The alleged defects affect 2011 to 2014 model-year GM vehicles. Plaintiffs 20 assert claims under various state consumer-protection and fraud statutes on behalf of a nationwide 21 class as well as various statewide classes. Plaintiffs filed their class action complaint on 22 December 19, 2016. See Docket No. 2 (“Compl.”). They have since amended their pleadings 23 several times; the operative complaint is the Eighth Amended Complaint. 24 Before the Court are (1) Plaintiffs’ motion for determination of Garet Tarvin’s adequacy to 25 serve as the California class representative pursuant to Federal Rule of Civil Procedure 23(a)(4), 26 see Docket No. 413 (“Tarvin Adequacy Mot.”) and (2) GM’s motion for partial summary 27 judgment pursuant to Federal Rule of Civil Procedure 56 on Mr. Tarvin’s claims, see Docket No. 1 As discussed below, the Court finds that Mr. Tarvin is an adequate representative for the 2 California Class. The Court thus GRANTS Plaintiffs’ motion for a determination of Mr. Tarvin’s 3 adequacy and appoints Mr. Tarvin to serve as a representative for the California Class. The Court 4 GRANTS in part and DENIES in part GM’s motion for partial summary judgment on Mr. 5 Tarvin’s claims. The Court GRANTS summary judgment for GM as to Mr. Tarvin’s claims for 6 unjust enrichment and fraudulent omission, and denies it as to the remainder of Mr. Tarvin’s 7 claims. 8 II. BACKGROUND 9 A. Factual Background 10 Plaintiffs allege that GM’s Gen IV Vortec 5300 LC9 engine suffers from an “inherent” oil- 11 consumption defect (the “Oil Consumption Defect”). See Docket No. 412 (“8AC”) ¶ 7. The 12 “primary cause” of the alleged defect is the piston rings installed by GM. Id. ¶ 8. These piston 13 rings “do not maintain sufficient tension to keep oil in the crankcase,” and the oil migration that 14 occurs as a result allows oil to “burn[] or accumulate[] as carbon buildup on the combustion 15 chamber’s surfaces.” Id. ¶¶ 8–9. Plaintiffs allege that the oil-consumption defect causes safety 16 problems in three ways: (1) oil consumption can lead to a lack of adequate lubrication in the 17 engine and dropping oil pressure levels in vehicles, see id. ¶ 19; (2) the presence of excess oil in 18 the combustion chamber can cause spark plug fouling, which can cause engine problems, see id.; 19 and (3) when drivers experience these problems while driving, they may be forced to pull over and 20 stop alongside a road or highway (or they may be stranded in such a location with an inoperable 21 vehicle), which places them in danger, see id. ¶¶ 14, 127–28. 22 B. Procedural Background 23 At this point in the litigation, the claims of ten plaintiffs remain in the case, and are set for 24 trial on September 13, 2022. See Docket No. 411 (“Scheduling Order”). The Court certified three 25 of those claims for class action trials under Rule 23(b)(3): (1) breach of implied warranty under 26 California’s Song-Beverly Consumer Warranty Act; (2) breach of implied warranty under North 27 Carolina law; and (3) violation of the Idaho Consumer Protection Act. See Docket No. 354 1 of model year 2011-2014 Chevrolet Avalanche, Silverado, Suburban, Tahoe, and GMC Sierra, 2 Yukon, and Yukon XL vehicles equipped with aluminum block LC9 Gen IV engines that were 3 manufactured after February 10, 2011. Docket No. 451 (“Joint Pretrial Conference Statement”) at 4 1–2. The California class is further limited to current owners who purchased their vehicles in new 5 condition and the Idaho class is further limited to current owners who purchased their vehicles 6 from GM dealerships. Id. at 1. There remain numerous individual claims. See September 7, 2021 7 Order at 2-4. On January 7, 2022, the Court granted in part and denied in part the parties’ Daubert 8 motions. Docket No. 395. 9 C. California Class Representatives 10 The Court initially appointed Plaintiff Raul Siqueiros as the California class representative, 11 but Mr. Siqueiros was not a class member because his vehicle was manufactured before February 12 10, 2011. See Docket No. 320 (“May 25, 2021 Order”) at 44. On June 26, 2020, Manuel 13 Fernandez moved to intervene and to be appointed as class representative for the California class. 14 Docket No. 278. On May 25, 2021, the Court appointed Mr. Fernandez as a class representative 15 for the California class. Id. at 45. In April 2022, Mr. Fernandez sold his Class Vehicle and was 16 no longer a current owner or class member, leaving the California case without a named plaintiff 17 in this action that is a California resident and able to serve as a California Class representative at 18 trial. See Docket No. 401 (“Mot. to Intervene”) at 1–2. 19 On May 13, 2022, Garet Tarvin and Carlos Gamez moved to intervene and to be appointed 20 as substitute California class representatives. See Mot. to Intervene at 1. On July 7, 2022, the 21 Court conditionally allowed Mr. Tarvin and Mr. Gamez1 to intervene, subject to the Court’s 22 determination after discovery that they are adequate class representatives under Rule 23. See 23 Docket No. 410 (July 7, 2022 Minute Order). On July 14, 2022, Plaintiffs moved for a 24 determination of Mr. Tarvin’s and Mr. Gamez’s adequacy as California class representatives. 25 Docket No. 413 (“Tarvin Adequacy Mot.”). On August 3, 2022, GM filed its opposition. Docket 26

27 1 On July 25, 2022, Mr. Gamez voluntarily dismissed all of his claims. Docket No. 418 (Notice of 1 No. 425 (“Tarvin Opp.”). On August 10, 2022, Plaintiffs filed their reply. Docket No. 438 2 (“Tarvin Adequacy Reply”). 3 On August 3, 2022, in conjunction with its opposition to Tarvin’s motion to be appointed a 4 representative of the California Class, GM moved for summary judgment on Tarvin’s individual 5 claims. See Docket No. 428 (“Tarvin MSJ”) at 1. On August 10, 2022, Plaintiffs filed their 6 opposition to GM’s motion for summary judgment. See Docket No. 439 (“Tarvin MSJ Opp.”). 7 The Court heard oral argument on both motions on August 26, 2022 as part of the pretrial 8 conference. Docket No. 470. 9 III. LEGAL STANDARDS 10 A. Motion for Adequacy of Class Representative 11 Although expressly authorized by Rule 23, the “class action is ‘an exception to the usual 12 rule that litigation is conducted by and on behalf of the individual named parties only.’” Wal– 13 Mart Stores, Inc. v. Dukes, 564 U.S. 338, 348 (2011) (quoting Califano v. Yamasaki, 442 U.S. 14 682, 700–01 (1979)). “In order to justify departure from that rule, ‘a class representative must be 15 part of the class and possess the same interest and suffer the same injury as [her fellow] class 16 members.’” Id. (quoting E. Tex. Motor Freight Sys., Inc. v. Rodriguez, 431 U.S. 395, 403 (1977)).

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