Judge: Michael Small, Case: 23STCV06998, Date: 2024-03-06 Tentative Ruling

Inform the clerk if you submit on the tentative ruling. If moving and opposing parties submit, no appearance is necessary.


Case Number: 23STCV06998    Hearing Date: March 6, 2024    Dept: 57

 

Plaintiffs Jose Villanueva and Reyna Luviano brought an action under the Song-Beverly Consumer Warranty Act (“Song-Beverly Act”) against Defendants Glendale Dodge, LLC dba Glendale Dodge Chrysler Jeep (“Glendale Dodge”) and FCA US LLC (“FCA”).   Plaintiffs allege that (1) on June 29, 2017, they entered into a warranty contract with FCA regarding a 2017 Dodge Challenger (“Subject Vehicle”) manufactured by FCA and sold by Glendale Dodge; (2) within the express warranty period, the Subject Vehicle had defects and nonconformities to the warranty, including electrical, interior, exterior and engine problems; and (3) Plaintiffs delivered the Subject Vehicle to an authorized FCA repair facility for repair, which was unable to conform the Subject Vehicle to the warranty after a reasonable number of attempts.  Plaintiffs further allege that FCA failed to replace the Subject Vehicle or make restitution under the Song-Beverly Act.  Plaintiffs seek, inter alia, a civil penalty of up to twice the amount of actual damages for FCA’s willful failure to comply with its obligations under the Song-Beverly Act.

Pending  before the Court are two discovery motions that Plaintiffs filed.  One motion seeks an order  compelling FCA to provide further responses to Plaintiffs’ first set of Special Interrogatories, numbers 45-48.  The other motion seeks an order compelling FCA to provide further responses to requests for production numbers 45 and 46. Plaintiffs also seek monetary sanctions against FCA in both motions.   Having considered the parties’ arguments, the Court is granting the motions to the extent they seek an order compelling further responses but denying the motions to the extent they seek sanctions.  FCA must provide further the further responses that Plaintiffs are seeking within 30 days of this order.

 SPECIAL INTERROGATORIES

 The special interrogatories that are the subject of the Plaintiffs’ motion, numbers 45-48, seek the following information:

             45.         At the time of release for the 2017 Dodge CHALLENGER vehicles, state your anticipated range for repairs per thousand vehicles sold (R/1000).

46.         State the repairs per thousand vehicles sold (R/1000) for 2017 Dodge CHALLENGER vehicles.

47.         Identify in order the five symptoms with the highest repairs per thousand (R/1000) for 2017 Dodge CHALLENGER vehicles, and the corresponding repairs per thousand.

48.         Identify in order the five components with the highest repairs per thousand (R/1000) for 2017 Dodge CHALLENGER vehicles, and the corresponding repairs per thousand.

  To each of these interrogatories, FCA responded with following objections: "
FCA US objects because this interrogatory seeks information that is not relevant to the subject matter of this litigation and is therefore not reasonably calculated to lead to the discovery of admissible evidence. . . . FCA US further objects that this interrogatory is vague, ambiguous, and overbroad; as a result, it is harassing, oppressive, and burdensome."         

The burden is on FCA as the responding party to establish facts necessary to justify its objections. (
Coy v. Superior Court (1962) 58 Cal.2d 210, 220-221; Fairmont Ins. Co. v. Superior Court (2000) 22 Cal.4th 245, 255.)  In the Court’s view, FCA has failed to carry that burden.

Relevance         

FCA argues that interrogatories 45-48 “bear no relevance to . . . whether Plaintiffs’ vehicle suffered a non-conformity and, if so, whether FCA . . . failed to conform the vehicle to warranty within a reasonable number of repair attempts. And, if the failure to conform the vehicle to warranty substantially impaired the vehicle’s use, value or safety. Nothing else is in issue.” (Opposition, p. 3.)  

 The Court disagrees.   In the Court’s view, special  interrogatories 45-48 are probative of whether FCA had reason to know that its 2017 Dodge Challenger vehicles were experiencing an abnormally high number of warranty repairs regarding the same problems that Plaintiff experienced with the Subject Vehicle.  As Plaintiffs correctly observe,  not only would this information be relevant to demonstrating that a defect likely existed in the Subject Vehicle, but it would also show that FCA failed to provide remedy to Plaintiffs even though it knew that vehicles of the same make model, and year were suffering from widespread warranty problems and thus evinces a willful violation of the Song-Beverly Act for which a civil penalty is warranted.

 Overbreadth and Ambiguity

The Court finds that the special interrogatories are appropriately tailored and not overbroad.
  Nor are the special interrogatories ambiguous -- they are clear and capable of being responded to.

Undue Burden

 FCA also objected on the ground that interrogatories 45-48 are “oppressive” and “burdensome.”  The showing required for an objection based on an asserted burden to be sustained is “detailed evidence showing precisely how much work is required to answer”; it is not enough that the questions will require a lot of work to answer. (Weil & Brown, Cal. Practice Guide: Civil Procedure Before Trial (The Rutter Group 2023) ¶¶ 8:1095-8:1097.)  FCA failed to carry that burden.  Its contention that “[t]here are hundreds of agents that process Song Beverly claims for the State of California and each one operates on a case-by-case basis” is conclusory and insufficient.

 REQUESTS FOR PRODUCTION

Plaintiffs move for an order compelling FCA’s further responses to their first set of Requests for Production (“RFP”) on the ground that FCA has not provided responses to RFP numbers 45 and 46 compliant with Code of Civil Procedure section 2031.310. Number 45 seeks documents evidencing complaints by owners of 2017 Dodge Challenger vehicles that are similar to any of Plaintiffs’ complaints for which they presented their Subject Vehicle to FCA or its authorized repair facilities during the warranty period. Number 46 seeks documents evidencing warranty repairs to any of the components of 2017 Dodge Challenger vehicles that FCA’s authorized repair facilities performed.

Plaintiffs bear the burden of showing good cause for the production of the documents in question.  The Court concludes that Plaintiffs have carried that burden.. Specifically, the documents sought in RFP numbers 45 and 46 are relevant to the issue whether FCA willfully violated the Song-Beverly Act in the face of knowledge of similar complaints and warranty repairs.  The burden thus shifts to FCA to justify its objections to the RFPs.  The Court concludes that FCA failed to carry that burden. Contrary to FCA’s assertion, the RFPs are not vague, ambiguous, or overly broad.  

The information to be produced in response to RFPs 45 and 46 shall be limited to California owners’ complaints and warranty repairs performed in California. 

 SANCTIONS

 While the Court disagreed with FCA’s position in connection with the discovery requests that were the subject of Plaintiffs’ motions, the Court has determined that FCA’s position was substantially justified. For that reason, sanctions against FCA are unwarranted.