Floyd v. American Honda Motor, Co., No. 18-55957 (9th Cir. 2020)
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Plaintiffs filed a putative class action raising warranty claims arising out of crashes or injuries caused by the alleged "rollaway effect" of certain Honda Civic vehicles. The district court dismissed plaintiffs' claims under the Magnuson-Moss Warranty Act (MMWA) and state law for express and implied warranty against Honda.
The Ninth Circuit held that the Class Action Fairness Act (CAFA) may not be used to evade or override the MMWA's specific numerosity requirement. In this case, plaintiffs name only three individuals, but argue that, by satisfying CAFA requirements, they are relieved of the MMWA's obligation to name at least one hundred plaintiffs. The panel rejected plaintiffs' argument and affirmed the district court's dismissal of the MMWA claim. The panel vacated the district court's dismissal of the state law claims, holding that the district court erred in not considering whether plaintiffs' state law claims met the diversity requirements of CAFA even if the MMWA claim failed. Therefore, the district court improperly dismissed the state law claims based only on lack of supplemental jurisdiction.
Court Description: Magnuson-Moss Warranty Act/Class Action Fairness Act The panel affirmed in part and vacated in part the district court’s dismissal of a putative class action raising warranty claims under the Magnuson-Moss Warranty Act and state law arising out of crashes or injuries caused by the alleged “rollaway effect” of certain Honda Civic vehicles. The parties disputed whether the district court’s order of dismissal was final and appealable. The panel held that it had jurisdiction to review the dismissal because the subsequent final disposition of the case by a final order cured any prematurity of plaintiffs’ appeal. Affirming the dismissal of the federal MMWA claim, the panel held that the Class Action Fairness Act does not override the MMWA’s requirement to name one hundred plaintiffs. * The Honorable Danny J. Boggs, United States Circuit Judge for the U.S. Court of Appeals for the Sixth Circuit, sitting by designation. FLOYD V. AMERICAN HONDA MOTOR CO. 3 Vacating the dismissal of plaintiffs’ state law claims based on lack of supplemental jurisdiction and remanding, the panel held that the district court erred in failing to consider whether the state law claims met the diversity requirements of CAFA even if the MMWA claim failed.
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