Vehicle Manufacturer Wins Summary Judgment on Keyless Entry System Claims

October 26, 2016

The U.S. District Court for the Central District of California recently granted Maserati, North America, summary judgment in a proposed class action concerning the manufacturer’s Ghibli model remote keyless entry system.  See Elsayed v. Maserati N. Am., Inc., Case No.: SACV 16-00918-CJC (DFMx), 2016 U.S. Dist. LEXIS 144238 (C.D. Cal. Oct. 18, 2016).  In dismissing the case, the court took a stringent view on warranty claims based upon language from vehicle user manuals, stating that vehicle manufacturers need not “state the obvious” to plaintiffs.

The plaintiff’s claims particularly concerned the remote keyless entry system for his family Ghibli.  The key fob for the remote keyless entry system permits the driver to unlock the vehicle without activating any key fob button. The plaintiff claimed the remote keyless entry system has a deadly defect that allows children to lock themselves inside the vehicles. The plaintiff’s son locked himself in the family Ghibli by accessing his mother’s key fob in her purse within the vehicle. The child remained locked in the vehicle for approximately 10 to 15 minutes.

The plaintiff asserted, individually and on behalf of all current and former owners of 2014-2016 model year Ghibli vehicles, 10 counts against the vehicle manufacturer, including allegations of violations of the Magnuson-Moss Warranty Act, breach of express warranty, breach of implied warranty of fitness for a particular purpose, breach of implied warranty of merchantability, products liability negligence claims, violation of the California Consumers Legal Remedies Act, and violation of California Unfair Competition Law. The plaintiff pointed to the vehicle manual and accompanying quick reference guide as the basis for warranty claims. 

The court, in evaluating Maserati’s motion for summary judgment on all claims, noted that the Ghibli manual expressly states that the remote keyless entry system unlocks the vehicle only if: (1) the ignition switch is off; (2) the vehicle has at least one open door; (3) the door trim panel lock button is pressed; and (4) after all doors are closed, the car detects a key fob inside the car without another key fob outside. As the plaintiff’s child’s incident clearly did not meet these parameters, and further, the plaintiff had no evidence of any system malfunction, the court found no express warranty breached as a matter of law. Similarly, the court found the manufacturer made no unfair or misleading misrepresentations regarding the functionality of the remote keyless entry system, thus precluding the California statutory claims.

The court also found no breach of implied warranty. The plaintiff’s situation — i.e., locking a person in a vehicle — can happen in a multitude of ways. The court noted that the Maserati design eliminates at least one of the ways a person may become locked in a vehicle. The choice to preclude only one way, rather than all ways, does not render the vehicle unmerchantable or unfit for providing safe transportation.

Finally, the court found that the economic loss rule precluded the products liability claims. Economic loss doctrine bars recovery for economic damages in a negligence-based action. The plaintiff’s main claim for damages concerned his perceived lack of benefit from the purchase price of the vehicle. The additional claims for emotional distress failed because the plaintiff did not himself witness the lock-out, and as a matter of law, no “special relationship” existed between the plaintiff and Maserati. Therefore, the court dismissed all products liability claims against the vehicle manufacturer.

The court’s literal reading of the vehicle manual language is a positive development for litigants confronting similar warranty claims. Moreover, the court’s adherence to the economic loss doctrine demonstrates that a plaintiff has no “special relationship” with a vehicle manufacturer. On balance, the court’s opinion would seem to narrow the effectiveness of common consumer claims against vehicle manufacturers for remote locking features.