Steven Charles Poston v. General Motors, LLC, a limited liability company; Does 1 through 10, inclusive

CourtDistrict Court, S.D. California
DecidedJuly 22, 2024
Docket3:24-cv-00082
StatusUnknown

This text of Steven Charles Poston v. General Motors, LLC, a limited liability company; Does 1 through 10, inclusive (Steven Charles Poston v. General Motors, LLC, a limited liability company; Does 1 through 10, inclusive) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Steven Charles Poston v. General Motors, LLC, a limited liability company; Does 1 through 10, inclusive, (S.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 STEVEN CHARLES POSTON, Case No. 24-cv-0082-BAS-JLB

12 Plaintiff, ORDER: 13 v. 1. GRANTING IN PART AND DENYING IN PART 14 GENERAL MOTORS, LLC, a limited DEFENDANT’S MOTION TO liability company; DOES 1 through 10, 15 DISMISS (ECF No. 5), and inclusive, 2. DENYING DEFENDANT’S 16 Defendants. REQUEST FOR JUDICIAL 17 NOTICE (ECF No. 5-2)

19 This case is about an allegedly defective electric car purchased by the plaintiff and 20 manufactured by the defendant. The plaintiff has sued the defendant car manufacturer, 21 alleging breach of warranty claims under the Song-Beverly Act as well as claims for 22 common-law fraud and violation of California’s Unfair Competition Law (“UCL”). 23 Presently before the Court is Defendant General Motors, LLC’s (“GM” or 24 “Defendant”) Motion to Dismiss the Complaint of Plaintiff Steven Charles Poston 25 (“Poston” or “Plaintiff”). (ECF No. 5.) Defendant moves to dismiss on the grounds that 26 Plaintiff fails to plead a claim upon which relief may be granted. (Id.) Plaintiff opposes. 27 (ECF No. 6.) Defendant replies. (ECF No. 7.) Defendant additionally requests judicial 28 notice of publicly available information. (ECF No. 5-2.) Plaintiff does not oppose. 1 The Court finds the motions suitable for determination on the papers submitted and 2 without oral argument. Fed. R. Civ. P. 78(b); CivLR 7.1(d)(1). For the reasons set forth 3 below, the Court DENIES Defendant’s Request for Judicial Notice (ECF No. 5-2), and 4 GRANTS IN PART and DENIES IN PART Defendant’s Motion to Dismiss the 5 Complaint (ECF No. 5). 6 I. BACKGROUND 7 Poston brings this automobile “lemon law” and fraud action against GM, alleging 8 the vehicle Poston purchased, manufactured by GM, does not function as GM represented 9 it would. On either April 29, 2021, or September 6, 2020, Poston purchased a new 2021 10 Chevrolet Bolt from “Kearny Mesa Chevrolet, an authorized dealer and agent of 11 [GM].” (ECF No. 1-2, Ex. A (“Compl.”) ¶¶ 4–6, 25.) As part of that transaction, GM 12 “issued an express warranty which would only be issued by [GM] as a result of the sale of 13 the vehicle.” (Id. ¶ 6.) GM does “not sell vehicles directly to members of the general 14 public.” (Id.) According to Poston, however, the sale of the Bolt by a GM dealership, 15 coupled with the issuance of the express warranty, created a transactional and contractual 16 relationship between GM and Poston such that the dealership was an agent of GM for the 17 purpose of the transaction. (Id.) At the time Poston acquired the Bolt in 2020 or 2021, 18 GM had advertised it “as a long range . . . electric vehicle on its website,” and GM 19 “dealership personnel assured Plaintiff of the long-range and safe nature of the vehicle.” 20 (Id. ¶ 26.) 21 When it announced production of the Bolt in October 2015, GM touted the Bolt as 22 an affordable, long-range vehicle. (Id. ¶ 14.) Then, in a January 2016 press release, GM 23 represented that the Bolt would have a battery range over 200 miles because GM had 24 improved the battery’s thermal operating performance. (Id. ¶ 15.) 25 By December 2016, GM became aware of issues with the Bolt’s battery and energy 26 management systems; in response, GM instituted a battery exchange program to replace 27 defective Bolt batteries. (Id. ¶ 16.) Despite this knowledge, GM began running 28 1 commercials in January 2017 that featured the range of the Bolt’s battery and advertised 2 the Bolt as a “long range” vehicle. (Id. ¶ 17.) 3 In October 2017, the National Highway Traffic Safety Administration (“NHTSA”) 4 “published a warning that overcharging lithium ion batteries, such as the battery in the Bolt, 5 can result in spontaneous ignition.” (Id. ¶ 18.) In November 2017 and April 2018, GM 6 created Bolt repair programs in response to “issues with low voltage batteries” and “to 7 update the vehicle’s software for a low voltage condition and reports of vehicles losing 8 propulsion.” (Id. ¶¶ 19–20.) Then, in August 2018, GM “created another program related 9 to the battery’s software and its ability to monitor the charge of the battery.” (Id. ¶ 22.) 10 A little over six months later, in March 2019, GM became aware of the first battery 11 fire involving the Bolt. (Id. ¶ 23.) Despite GM’s knowledge of the fire risk posed by 12 charging the battery to full capacity, in October of that same year, GM held an event to 13 address questions regarding the Bolt, and one of its employees and Bolt battery expert, 14 Adam Piper, stated the following: “We engineered the battery system so that you can 15 charge to 100% and maximize range. Do whatever is best for your personal circumstances. 16 If you want maximum range, charge to 100%.” (Id. ¶ 24.) By August 2020, GM “was 17 aware of at least [twelve] fires” involving the Bolt. (Id. ¶ 25.) Yet, GM did not “disclose 18 the battery issues to Plaintiff or alter its marketing campaign” for the Bolt. (Id. ¶ 23) The 19 marketing materials for the 2020 Bolt pictured the vehicle as capable of being charged 20 indoors in a garage. (Id. ¶ 29.) 21 In October 2020, the NHTSA opened an investigation into the Bolt specifically. (Id. 22 ¶ 27.) Then, on an unspecified date in 2021, GM issued a recall notice for the Bolt, “stating 23 that its batteries may ignite when nearing a full charge.” (Id. ¶ 30.) Through this recall, 24 GM “warned Plaintiff that the vehicle’s charge should not exceed 90%, the battery mileage 25 should not fall below seventy (70) miles remaining, and the vehicle should not be parked 26 indoors overnight.” (Id.) 27 In sum, GM “marketed the subject vehicle in [a] false and misleading manner by 28 advertising it as safe and function[al],” when in fact it “is neither safe nor functional for 1 normal use due to the presence of defective and dangerous lithium-ion battery modules.” 2 (Id. ¶ 28.) In fact, the vehicle’s “batteries may ignite when they are either fully charged or 3 fall below seventy (70) miles remaining mileage,” and “[t]he vehicle also cannot be parked 4 inside overnight due to fire risk.” (Id. ¶ 13.) These alleged affirmative misrepresentations 5 and fraudulent omissions by Defendant caused Poston to suffer injury in the form of 6 anxiety, fear, and emotional distress. (Id. ¶¶ 32, 44, 93.) 7 In his Complaint, Poston brings five claims against GM under California law: three 8 claims of breach of warranties in violation of the Song-Beverly Consumer Warranty Act; 9 a claim of common-law fraud; and a claim under California’s UCL, California Business 10 and Professions Code §§ 17200, et seq.. (Compl. at 1.) 11 GM moves to dismiss Poston’s fourth and fifth claims. (ECF No. 5.)1 GM argues 12 Poston fails to plead each element of his fraud claims and argues that the economic loss 13 rule bars one of his theories of liability. (See id.) GM further argues that Poston fails to 14 plead his UCL claims because he does not specifically state a predicating statute and fails 15 to reference any established public policy GM’s actions may have violated. (See id.) 16 II. LEGAL STANDARDS 17 A. Rule 12(b)(6) Motion to Dismiss 18 General Motors brings this motion pursuant to Federal Rule of Civil Procedure 19 (“Rule”) 12(b)(6). Under Rule 12(b)(6), the Court may dismiss a cause of action for 20 “failure to state a claim upon which relief can be granted.” Fed. R. Civ. P. 12(b)(6). “A 21 Rule 12(b)(6) dismissal may be based on either a ‘lack of a cognizable legal theory’ or ‘the 22 absence of sufficient facts alleged under a cognizable legal theory.’” Johnson v. Riverside 23 24

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Steven Charles Poston v. General Motors, LLC, a limited liability company; Does 1 through 10, inclusive, Counsel Stack Legal Research, https://law.counselstack.com/opinion/steven-charles-poston-v-general-motors-llc-a-limited-liability-company-casd-2024.