Wheeler v. LG Electronics USA, Inc.

CourtDistrict Court, E.D. California
DecidedJanuary 4, 2024
Docket1:22-cv-00459
StatusUnknown

This text of Wheeler v. LG Electronics USA, Inc. (Wheeler v. LG Electronics USA, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wheeler v. LG Electronics USA, Inc., (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 MARK WHEELER, individually and on No. 1:22-cv-00459-NODJ-BAM behalf of all others similarly situated, 12 Plaintiff, 13 ORDER GRANTING DEFENDANT’S v. MOTION TO COMPEL ARBITRATION AND 14 DENYING AS MOOT DEFENDANT’S LG ELECTRONICS USA, INC., MOTION TO TRANSFER VENUE, OR IN 15 THE ALTERNATIVE, TO DISMISS Defendant. 16 (Doc. Nos. 18, 19, 30)

17 18 19 This matter is before the court on (1) the motion to transfer venue, or in the alternative, to 20 dismiss, and (2) the motion to compel arbitration filed by defendant LG Electronics USA, Inc., 21 (“LG”) on August 5, 2022, and February 23, 2023, respectively. (Doc. Nos. 18, 30.) In light of 22 the public health emergency posed by the COVID-19 pandemic, defendant’s motion to transfer 23 venue was taken under submission by the then-assigned district judge on the papers on August 8, 24 2022. (Doc. No. 20.) Defendant’s motion to compel arbitration was likewise taken under 25 submission on the papers on February 27, 2023. (Doc. No. 31.) For the following reasons, the 26 court will grant defendant’s motion to compel arbitration and deny as moot the motion to transfer 27 venue or dismiss. 28 ///// 1 BACKGROUND 2 A. Factual Background 3 Plaintiff Mark Wheeler filed a complaint initiating this putative class action on April 19, 4 2022, involving several models of defendant LG’s dishwashers.1 (Doc. No. 1.) Therein, plaintiff 5 alleges the following. Defendant LG knowingly sold dishwashers equipped with defective LED 6 control panels. (Id. at ¶ 4.) Specifically, according to plaintiff, the defect “allows moisture to 7 penetrate the Control Panels, damaging the sensitive electronic components housed therein.” (Id.) 8 The defect can make the control panels unresponsive, causing dishwashers to stop during a cycle 9 or fail to restart, which ultimately prevents consumers from using their dishwashers as expected 10 and intended. (Id.) Defendant knew or had reason to know of the defect since 2015 based on 11 consumer complaints. (Id. at ¶ 5); see also id. at 22 (providing a product review dated April 12, 12 2015, concerning, among other things, the replacement of a control panel). Defendant 13 acknowledged the defect on November 8, 2018, in a service bulletin made available only to its 14 authorized repair technicians but “failed to disclose and actively concealed this material fact from 15 Plaintiffs and the Class.” (Id. at ¶¶ 5, 6.) 16 Plaintiff’s allegations, as they relate to himself, are as follows. Plaintiff, a California 17 resident, purchased an LG dishwasher, model number LDT5678SS, from a Lowes Store in 18 Bakersfield, California on November 29, 2019. (Id. at ¶¶ 13, 14.) Prior to purchase, plaintiff 19 researched and reviewed several dishwashers on defendant’s website which were advertised as 20 energy efficient and helpful in the reduction of water consumption. (Id. at ¶ 15.) However, 21 neither defendant nor any of its representatives informed plaintiff of the dishwasher’s control 22 panel defect. (Id.) Following his purchase, in July of 2020, plaintiff contacted defendant 23 regarding the defect,2 at which point defendant provided a replacement control panel pursuant to 24 the product’s warranty. (Id. at ¶ 16.) In February of 2021, plaintiff’s replacement control panel 25

1 Specifically, this action involves “model numbers: LDF5545, LDP6797, LDT7797, LDT5665, 26 LDT5678, and LDT7808.” (Doc. No. 1 at ¶ 1.) 27 2 Plaintiff does not specifically allege how he first learned of the defect, though presumably, his 28 dishwasher began malfunctioning at that time, prompting him to contact defendant. 1 began malfunctioning by powering on and off during cycles. (Id. at ¶ 17.) “Upon inspection, the 2 technician concluded that the Control Panel would need to be replaced again[,]” which left 3 plaintiff with a defective dishwasher because by that point, the warranty had expired. (Id.) 4 Plaintiff does not allege that he contacted defendant a second time to replace the defective control 5 panel after the warranty had expired. 6 Plaintiff further alleges that defendant continues to provide consumers with replacement 7 control panels which suffer from the same moisture-penetration defect. (Id. at ¶¶ 8, 9.) 8 Defendant’s warranty allegedly “fails of its essential purpose[]” because “once LG’s one-year 9 ‘labor and parts’ warranty expires, LG claims the Defect does not exist, declines to provide 10 further warranty coverage, and requires consumers who have not purchased an extended warranty 11 to pay out of pocket to (temporarily) return their Class Dishwashers to proper working order[.]” 12 (Id. at ¶ 9.) Thus, plaintiff contends that defendant’s actions leave impacted consumers with the 13 unsatisfactory choice between purchasing a new defect-free dishwasher or paying for multiple 14 repairs on their defective dishwasher model. (See id. at ¶ 11.) 15 The warranty covering plaintiff’s particular dishwasher model contains an arbitration 16 provision stating: 17 ARBITRATION NOTICE: THIS LIMITED WARRANTY CONTAINS AN ARBITRATION PROVISION THAT REQUIRES 18 YOU AND LG TO RESOLVE DISPUTES BY BINDING ARBITRATION INSTEAD OF IN COURT, UNLESS YOU 19 CHOOSE TO OPT OUT. IN ARBITRATION, CLASS ACTIONS AND JURY TRIALS ARE NOT PERMITTED. PLEASE SEE THE 20 SECTION TITLED “PROCEDURE FOR RESOLVING DISPUTES” BELOW. 21 22 (Doc. No. 30-3 at 57.) This provision appears in an owner’s manual which has been packaged 23 with all LG dishwashers since at least March 2018. (Doc. No. 30-2 at ¶ 4.) Specifically, the 24 above provision appears on the fifty-sixth page of the owner’s manual, and the relevant excerpts 25 quoted in this order are from the version of the owner’s manual that was revised on July 30, 2019, 26 and effective when plaintiff purchased his dishwasher in November 2019. (Id. at ¶¶ 7–16.) 27 In a paragraph defining terms, the owner’s manual provides that references to the term 28 “dispute” include “any dispute, claim or controversy of any kind whatsoever (whether based in 1 contract, tort, statute, regulation, ordinance, fraud, misrepresentation or any other legal or 2 equitable theory) arising out of or relating in any way to the sale, condition or performance of the 3 product or this Limited Warranty.” (Doc. 30-3 at 59.) Regarding governing law, the owner’s 4 manual states that “[t]he law of the state of your residence shall govern this Limited Warranty and 5 any disputes between us except to the extent that such law is preempted by or inconsistent with 6 applicable federal law.” (Id.) The owner’s manual also sets forth the process for opting out of 7 arbitration: 8 Opt Out. You may opt out of this dispute resolution procedure. If you opt out, neither you nor LG can require the other to participate 9 in an arbitration proceeding. To opt out, you must send notice to LG no later than 30 calendar days from the date of the first consumer 10 purchaser’s purchase of the product by either: (i) sending an e-mail to optout@lge.com, with the subject line: “Arbitration Opt Out” or 11 (ii) calling 1-800-980-2973. 12 (Id. at 60.) Later, the same section provides that opting out will not affect the warranty’s 13 coverage and that “[i]f you keep this product and do not opt out, then you accept all terms and 14 conditions of the arbitration provision described above.” (Id.) 15 In addition to the arbitration provision contained within the owner’s manual, all LG 16 dishwashers have featured an arbitration notice both on the inside and outside of the product’s 17 packaging since at least March 2018 containing the following language: 18 By using this product, you agree that all disputes between you and LG arising out of or relating in any way to this product (including 19 but not limited to warranty disputes) shall be resolved exclusively through binding arbitration on an individual basis.

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Bluebook (online)
Wheeler v. LG Electronics USA, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/wheeler-v-lg-electronics-usa-inc-caed-2024.