Vo v. General Motors, LLC

CourtDistrict Court, S.D. California
DecidedNovember 14, 2024
Docket3:24-cv-00745
StatusUnknown

This text of Vo v. General Motors, LLC (Vo v. General Motors, LLC) 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
Vo v. General Motors, LLC, (S.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 9 UNITED STATES DISTRICT COURT 10 SOUTHERN DISTRICT OF CALIFORNIA 11 12 BRYAN VO, Case No.: 24-cv-745-WQH-SBC

Plaintiff, 13 ORDER v. 14 15 GENERAL MOTORS, LLC, a Delaware Limited Liability 16 Company; and DOES 1 through 17 10, inclusive, 18 Defendants. 19 HAYES, Judge: 20 The matter before the Court is the Motion to Dismiss Plaintiff’s Complaint for 21 Failure to State a Claim (“Motion to Dismiss”) (ECF No. 5) filed by Defendant General 22 Motors LLC (“Defendant” or “General Motors”). 23 I. BACKGROUND 24 On March 25, 2024, Plaintiff initiated this action by filing a Complaint in the 25 Superior Court of California, County of San Diego, Case No. 37-2024-00013864-CU-BC- 26 CTL. (ECF No. 1-2, Compl.) 27 On April 24, 2024, Defendant removed the action to this Court on the basis that the 28 Court has diversity jurisdiction over this dispute. (ECF No. 1.) 1 On April 30, 2024, Defendant filed the Motion to Dismiss. (ECF No. 5.) On May 2 14, 2024, Plaintiff filed a Response in opposition to the Motion to Dismiss. (ECF No. 6.) 3 On May 24, 2024, Defendant filed a Reply. (ECF No. 7.) 4 II. ALLEGATIONS IN THE COMPLAINT 5 In October 2015, Defendant “announced [a] partnership with LG to produce the 6 Chevrolet Bolt and touted the vehicle as an affordable, long range vehicle.” (Compl. ¶ 18.) 7 In a January 2016 press release, Defendant “said the Bolt will have a battery range over 8 200 miles because of the use of a battery with improved thermal operating performance.” 9 Id. ¶ 19. “The mileage representation was made absent any reference to the EPA estimated 10 mileage range.” Id. In December 2016, Defendant “first became aware of issues with the 11 battery in the Bolt.” Id. ¶ 20. “As a result of issues with the battery and energy management 12 related issues, General Motors instituted a Bolt EV High Voltage Battery Exchange and 13 Internal Parts Process to replace defective batteries.” Id. Despite this knowledge, 14 Defendant started to run commercials in January 2017 that featured the Bolt’s battery 15 range, marketing the Bolt as a “‘long range’ and ‘affordable’ vehicle.” Id. ¶ 21. 16 “In October 2017, [the National Highway Traffic Safety Administration 17 (‘NHTSA’)] published a warning that overcharging lithium ion batteries, such as the 18 battery in the Bolt, can result in spontaneous ignition.” Id. ¶ 22. 19 In November 2017, Defendant created a Bolt repair program “in response to findings 20 of issues with low voltage in the batteries.” Id. ¶ 23. 21 In April 2018, Defendant “created another program to update the vehicle’s software 22 for a low voltage condition and reports of vehicles losing propulsion.” Id. ¶ 24. In May 23 2018, Defendant “again notified its dealers regarding issues with the batteries in the Bolt.” 24 Id. ¶ 25. 25 In August 2018, Defendant “created another program related to the battery’s 26 software and its ability to monitor the charge of the battery.” Id. ¶ 26. 27 In March 2019, Defendant “became aware of the first battery fire involving the 28 Chevrolet Bolt.” Id. ¶ 27. 1 “Despite the foregoing, in October 2019, General Motors made Adam Piper, a 2 GENERAL MOTORS employee and Bolt battery expert, available to answer questions 3 regarding the Chevy Bolt.” Id. ¶ 28. “Mr. Piper, on behalf of [and as authorized to speak 4 on behalf of] GENERAL MOTORS, stated: ‘We engineered the battery system so that you 5 can charge to 100% and maximize range. Do whatever is best for your personal 6 circumstances. If you want maximum range, charge to 100%.’” Id. This statement was 7 made despite Defendant’s knowledge of the fire risk when fully charging the battery. 8 Defendant also created a marketing brochure for the 2020 Chevrolet Bolt that 9 “represent[ed] that the vehicle can be charged safely, at home, in a garage.” Id. ¶¶ 29–30. 10 “The marketing brochure also represents that the vehicle’s battery can be charged to 100 11 percent.” Id. ¶ 31. Defendant “knew this was not safe based upon the risk of fire that had 12 been reported in March 2019 and the previous advisory NHTSA in 2017 warning about 13 charging batteries to 100 percent.” Id. ¶ 30. Plaintiff reviewed the marketing brochure and 14 “relied on the representations … that the vehicle’s battery could be fully charged and could 15 be charged indoors safely.” Id. ¶¶ 29, 31. 16 On February 27, 2021, Plaintiff acquired a 2021 Chevrolet Bolt, VIN Number 17 1G1FZ6S00M4102793 (the “Subject Vehicle”) from Bob Stall Chevrolet, an authorized 18 dealer and agent of Defendant. As part of the transaction, Defendant issued express 19 warranties that the Subject Vehicle “would be free from defects in materials, 20 nonconformities, or workmanship during the applicable warranty period and to the extent 21 the SUBJECT VEHICLE had defects, GENERAL MOTORS would repair the defects” 22 and an 8-year, 100,000-mile warranty for the vehicle’s battery. Id. ¶ 11. “[A]t no time prior 23 to the sale of the subject vehicle did General Motors disclose the battery issues to Plaintiff 24 or alter its marketing campaign with respect to the subject vehicle.” Id. ¶ 27. 25 Plaintiff notified Defendant’s authorized service and repair facilities, within a 26 reasonable time after Plaintiff’s discovery, when the Subject Vehicle “exhibited defects, 27 non-conformities, misadjustments, or malfunctions.” Id. ¶ 14. On each notified occasion, 28 Plaintiff “attempted to invoke the applicable warranties, demanding that the authorized 1 repair facilities repair such nonconformities pursuant to the warranties.” Id. “Defendant 2 failed to make the SUBJECT VEHICLE conform to the applicable warranties, despite a 3 reasonable amount of time and a reasonable number of attempts to do so.” Id. ¶ 15. Plaintiff 4 discovered that Defendant “was unable or unwilling to make the SUBJECT VEHICLE 5 conform to the applicable warranties.” Id. ¶ 16. Defendant “falsely represented that the 6 subject vehicle is safe and functional for normal use.” Id. ¶ 17. The Subject Vehicle, 7 however, “is not safe or functional because the batteries may ignite when they are either 8 fully charged or fall below seventy (70) miles remaining mileage” and “cannot be parked 9 inside overnight due to fire risk.” Id. 10 “In 2021, Defendant GENERAL MOTORS issued a recall notice for the subject 11 vehicle, stating that its batteries may ignite when nearing a full charge.” Id. ¶ 32. Defendant 12 “warned Plaintiff that the vehicle’s charge should not exceed 90%, the battery mileage 13 should not fall below seventy (70) miles remaining, and the vehicle should not be parked 14 indoors overnight.” Id. 15 In December 2021, Plaintiff received a letter from Defendant’s Vice-President Steve 16 Hill, wherein Hill “represented to Plaintiff that General Motors would provide [him] with 17 a new battery for the subject vehicle that did not suffer from the safe [sic] defects as the 18 battery which was installed at the time of purchase.” Id. ¶¶ 49–50. “From December 2021 19 until June 2023, Plaintiff relied on Mr. Hill’s representation that [he] would receive a new 20 battery. Because of this representation, Plaintiff did not sell the vehicle or ask General 21 Motors to repurchase [his] vehicle.” Id. ¶ 52. In June 2023, however, Defendant “reneged 22 on Mr. Hill’s promise to replace Plaintiff’s battery.” Id. ¶ 51. 23 “For a period of time,” Defendant’s “policy was to repurchase vehicles such as 24 Plaintiff[’]s when asked to do so.” Id. ¶ 53. “In June 2023, GENERAL MOTORS sent 25 Plaintiff an e-mail that again stated [his] battery would be replaced.” Id. ¶ 54. But “shortly 26 thereafter GENERAL MOTORS told Plaintiff there had been a ‘misunderstanding’ and 27 that [his] battery would not in fact be replaced. When Plaintiff found out [he] would not 28 receive a new battery in June 2023 and requested GENERAL MOTORS repurchase [his] 1 vehicle,” Defendant “refused to do so and continue[s] to refuse to do so.” Id. ¶ 55.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Foman v. Davis
371 U.S. 178 (Supreme Court, 1962)
Schlesinger v. Councilman
420 U.S. 738 (Supreme Court, 1975)
Franklin v. Gwinnett County Public Schools
503 U.S. 60 (Supreme Court, 1992)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Shroyer v. New Cingular Wireless Services, Inc.
622 F.3d 1035 (Ninth Circuit, 2010)
Yuba Consolidated Gold Fields v. Kilkeary
206 F.2d 884 (Ninth Circuit, 1953)
Edwards v. Marin Park, Inc.
356 F.3d 1058 (Ninth Circuit, 2004)
Gary Davis v. Hsbc Bank Nevada, N.A.
691 F.3d 1152 (Ninth Circuit, 2012)
Asvesta v. Petroutsas
580 F.3d 1000 (Ninth Circuit, 2009)
Kearns v. Ford Motor Co.
567 F.3d 1120 (Ninth Circuit, 2009)
Cel-Tech Communications, Inc. v. Los Angeles Cellular Telephone Co.
973 P.2d 527 (California Supreme Court, 1999)
Moss v. U.S. Secret Service
572 F.3d 962 (Ninth Circuit, 2009)
In Re Vioxx Class Cases
180 Cal. App. 4th 116 (California Court of Appeal, 2009)
Tarmann v. State Farm Mutual Automobile Insurance
2 Cal. App. 4th 153 (California Court of Appeal, 1991)
Agosta v. Astor
15 Cal. Rptr. 3d 565 (California Court of Appeal, 2004)
Kaldenbach v. Mutual of Omaha Life Insurance
178 Cal. App. 4th 830 (California Court of Appeal, 2009)

Cite This Page — Counsel Stack

Bluebook (online)
Vo v. General Motors, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vo-v-general-motors-llc-casd-2024.