Spingola v. BMW of North America, LLC

CourtDistrict Court, N.D. California
DecidedNovember 15, 2019
Docket3:18-cv-00528
StatusUnknown

This text of Spingola v. BMW of North America, LLC (Spingola v. BMW of North America, LLC) 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
Spingola v. BMW of North America, LLC, (N.D. Cal. 2019).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 DARRELL SPINGOLA, 7 Case No. 18-cv-00528-JCS Plaintiff, 8 v. ORDER GRANTING IN PART AND 9 DENYING IN PART MOTION FOR BMW OF NORTH AMERICA, LLC, SUMMARY JUDGMENT 10 Defendant. Re: Dkt. No. 90 11

12 13 I. INTRODUCTION 14 In this action, Plaintiff Darell Spingola asserts claims for breach of express and implied 15 warranties under California’s lemon law, the Song Beverly Consumer Warranty Act, Cal. Civ. 16 Code § 1790, et seq. (“the Song Beverly Act”), against BMW of North America, LLC (“BMW”). 17 Presently before the Court is BMW’s Motion for Summary Judgment (“Motion”), in which BMW 18 argues that it is entitled to summary judgment on both of Spingola’s claims. Spingola conceded in 19 his response to the Motion that his claim for breach of implied warranty fails as a matter of law 20 and therefore, the Court GRANTS summary judgment on that claim in favor of BMW. The only 21 remaining question is whether BMW is entitled to summary judgment on Spingola’s claim for 22 breach of express warranty under the Song Beverly Act. The Court finds that it is not and 23 therefore DENIES summary judgment on that claim.1 24 II. BACKGROUND 25 On January 11, 2011, Spingola purchased a used BMW 535i Gran Turismo (the “Vehicle”) 26 with 9,353 miles on it from a BMW dealer. Joint Proposed Final Pretrial Order at 4 (“Stipulated 27 1 Facts”). It is undisputed that the Vehicle was sold subject to BMW’s new vehicle limited 2 warranty that covered defects in materials or workmanship for the earlier of four years or 50,000 3 miles from the Vehicle’s original in-service date of September 1, 2010. Id. Based on the parties’ 4 pretrial filings, it appeared that Spingola’s breach of express warranty claim was based on this 5 warranty. 6 Because Spingola’s pretrial filings did not clearly set forth the theory of his claims, the 7 Court asked Spingola’s counsel to identify the particular defects upon which his claims were 8 based at the pretrial conference that was held on August 9, 2019. Spingola’s counsel identified the 9 following defects that are the basis of his claim: 1) a defect in the VANOS system that caused oil 10 to build up and leak; and 2) improper recall work on the VANOS system that allowed 11 contaminants to flow through the engine, causing problems such as rough running and sputtering. 12 See Transcript of August 8, 2019 Pretrial Conference (Docket No. 88) at 3-4. The Court made 13 clear that Spingola would be held to these two defects as the basis of his claims. Docket No. 88 14 (Transcript of August 9, 2019 pretrial conference) at 16. 15 Spingola’s expert, Daniel Calif, explains in his expert report that VANOS refers to a 16 variable valve timing system that is used in 2010 BMW 5 series vehicles and that in some BMW 17 documents it is also referred to as “Valvetronic system.” Calef Decl., Ex. 4 (Calef Report) at 2; 18 see also Curtis Reply Decl., Ex. A (Calef Dep.) at 151 (testifying that the VANOS system and the 19 Valvetronic sytem are “intrinsically tied together” even though they are different systems). Calef 20 testified unequivocally at his deposition that the defects that are the basis of Spingola’s claim 21 began when the dealer performed recall work on the Vehicle’s VANOS system (“the VANOS 22 recall”), around February 15, 2015. See Rafael Decl., Ex. A (Calef Dep.) at 96-99. According to 23 Calef, after that time, several repair orders showed that error code 135604, which refers to 24 “Valvetronic system: no adjustment possible,” “ha[d] been set.” Calef Decl., Ex. 4 (Calef Report) 25 at 4 (listing Repair Orders 602037, 606253 and 620525); see also Barry Decl., Exs. 3-5 (Repair 26 Orders 602037, 606253 and 620525). Calef also states in his report that the value of the Vehicle is 27 substantially impaired as a result of the “VANOS defect” – which he describes as “an emissions 1 California but rather would have to be sold to a dealer.” Calef Decl., Ex. 4 (Calef Report) at 6. 2 In the Motion, BMW argues that it is entitled to summary judgment on Spingola’s breach 3 of express warranty claim because it is undisputed that the new vehicle limited warranty that 4 covered the Vehicle, which covered defects in materials or workmanship for the earlier of four 5 years or 50,000 miles from the Vehicle’s original in-service date of September 1, 2010, had 6 already expired when the VANOS problems began. Motion at 12-13. BMW further asserts that 7 there is no evidence of a VANOS defect – at least before September 1, 2014 when the new vehicle 8 warranty expired. Id. at 13. 9 In his Opposition brief, Spingola responds that his claim is not based on the four- 10 year/50,000 mile warranty but rather, on a seven-year/70,000 mile emissions warranty 11 (hereinafter, the “7/70,000 California Emissions Warranty”) that covers, among other things, the 12 VANOS system. Opposition at 2, 5-8 (citing Calef Decl., Ex. 2). Spingola argues that because 13 the VANOS issues he complained of began before this emissions warranty expired and there were 14 at least two repair attempts within that warranty period, there are disputed facts that preclude 15 summary judgment as to the breach of express warranties claim. Opposition at 5-10. Spingola 16 also argues that it is not his burden to prove the existence of a “defect” and that he is only required 17 to show that the Vehicle was not conformed to the express warranty. Id. at 3-5. 18 In its Reply brief, BMW argues that the Song-Beverly Act does require Plaintiff to prove 19 the existence of a defect and that the words “defect” and “noncomformity” are used 20 interchangeably in the Song-Beverly Act. Reply at 2-4. BMW further points out that Spingola 21 did not argue in his Opposition that there was evidence of a defect prior to the expiration of the 22 four-year/50,000 mile warranty, thus implicitly conceding that his claim fails to the extent it is 23 based on that warranty. Id. at 4. BMW does not dispute that the Vehicle is covered by the 24 7/70,000 California Emissions Warranty but argues that it does not apply in this case because 25 “[e]vidence of the threshold condition that is required to trigger the emissions warranty – a failed 26 smog test – does not exist” and this is “fatal to [Spingola’s] entire emissions warranty theory.” Id. 27 In support of this argument, BMW cites to language in the Vehicle’s warranty booklet stating that 1 Check test or upon discovery of the defect, to the workshop of any authorized BMW center, 2 during normal work hours.” Id. at 5 (citing Trial Exhibit 23, p. 35). 3 BMW further asserts that Spingola has not pointed to any evidence that there is a VANOS 4 defect and cites to Calef’s testimony that the Vehicle’s problem is oil contamination “caused by a 5 technician neglecting to perform an unprescribed oil change,” which BMW contends does not 6 constitute a manufacturer “defect” under the Song-Beverly Act. Id. BMW also points to Calef’s 7 testimony conceding that: 1) there was no evidence that the VANOS bolts that were replaced as 8 part of the recall were actually broken or that the VANOS system itself needed to be replaced 9 when the recall work was performed; 2) no VANOS codes ever came up in any of the Repair 10 Orders; and 3) the reference in his expert report to “VANOS system failures causing poor 11 performance and diagnostic trouble code 135604 to be set” was in error because this code actually 12 related to the Valvetronic system, which is a separate system. Id. at 7-11 (citing Curtis Reply 13 Decl., Ex. A (Calef Dep.) at 126-127, 136-137, 104, 106-107, 114, 151, 119).

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Spingola v. BMW of North America, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/spingola-v-bmw-of-north-america-llc-cand-2019.