Judge: Theresa M. Traber, Case: 19STCV41383, Date: 2025-02-14 Tentative Ruling




Case Number: 19STCV41383    Hearing Date: February 14, 2025    Dept: 47

LAOLU DAMILOLA OLADAPO vs BMW OF NORTH AMERICA, LLC, Case No. 19STCV41383

TENTATIVE RULINGS ON MOTIONS IN LIMINE

PLAINTIFF’S MIL # 1 – seeking order excluding any settlement discussions.

TENTATIVE RULING:  GRANTED, without opposition.

PLAINTIFF’S MIL # 2:  seeking order excluding any evidence or argument that Defendant proposed  arbitration as a resolution to this matter.   

TENTATIVE RULING:  GRANTED, without opposition, as such matters are not relevant to any claim or defense and are potentially prejudicial and, thus, should be excluded under Evidence Code § 352.  Because Plaintiff does not seek relief under Civil Code § 1794(e) or § 1793.22, evidence of the existence or Plaintiff’s use of Defendant’s optional arbitration program is irrelevant to the claims raised in this case.  Nor is the existence of Defendant’s arbitration program relevant to the question of whether its failure to repurchase or replace the vehicle was willful.  The existence of this program prior to Defendant’s failure has no probative value for the question of willfulness.  Similarly, its decision to refer Plaintiff that program is evidence of its failure to repurchase or replace the vehicle but says nothing about whether that failure was willful.  

PLAINTIFF’S MIL # 3:  seeking order excluding evidence and argument regarding Plaintiff’s ability to recover attorney’s fees.

TENTATIVE RULING:  GRANTED, without opposition, as such matters are not relevant to any claim or defense and are potentially prejudicial and, thus, should be excluded under Evidence Code § 352. 

PLAINTIFF’S MIL # 4:  seeking order excluding evidence and argument regarding Plaintiff’s application for financing and financial condition.

TENTATIVE RULING:  GRANTED, without opposition, as such matters are not relevant to any claim or defense and are potentially prejudicial and, thus, should be excluded under Evidence Code § 352. 

PLAINTIFF’S MIL # 5 – seeking order excluding evidence and argument regarding any advertising by Plaintiff’s attorneys.

TENTATIVE RULING:  GRANTED, without opposition, as such matters are not relevant to any claim or defense and are potentially prejudicial and, thus, should be excluded under Evidence Code § 352.  All counsel and parties will be introduced to prospective jurors who will be asked by the Court if they have ever heard of or know any of the parties, lawyers or law firms and, if so, how they came to hear of or know any of them.  The Court may inquire into any prior impressions these potential jurors have of any of the parties or lawyers, but this questioning may be conducted out of the earshot of other jurors, because of the potentially prejudicial impact of negative views of individual jurors. 

PLAINTIFF’S MIL # 6:  seeking order excluding evidence and argument that timely revocation of acceptance was required.

TENTATIVE RULING:  GRANTED, without opposition, as such matters are not relevant to any claim or defense.

Through this motion, Plaintiff raises the concern that Defendant will argue Plaintiff should be denied some or all relief on his Song-Beverly Consumer Warranty Act claims based on the contention that Plaintiff failed to give timely notice to the seller of revocation of acceptance of the vehicle.  Although the California Uniform Commercial Code generally requires that a buyer give notice of revocation of acceptance of goods within a reasonable time after their delivery (Comm. Code §§ 2602(1); 2607(3)(a)), the Song-Beverly Consumer Warranty Act, which contains more stringent consumer protections, does not require rejection or revocation of acceptance of a vehicle within a reasonable time or any time at all. (Civ. Code § 1793.2(d); Mexia v. Rinker Boat Co., Inc. (2009) 174 Cal.App.4th 1297, 1301, 1310; Krotin v. Porsche Cars North America, Inc. (1995) 38 Cal.App.4th 294, 300.)  As the Court of Appeal explained in Mexia, the Commercial Code’s requirements that revocation be given within a reasonable time after sale “do not apply to any action brought under the Song-Beverly Act. . . . If the Legislature intended the duration provision to impose a deadline for consumers to give notice of defects under the Song-Beverly Act, it could easily have done so.  It did not.”  (Ibid., at pp. 1307, 1310.)

PLAINTIFF’S MIL # 7:  seeking order establishing that statements made by Defendant’s dealership personnel (warranty agents) are non-hearsay and admissible, under Evidence Code §§ 1220 and 1224. 

TENTATIVE RULING:  GRANTED IN PART, subject to presentation of additional evidence about the basis for Plaintiffs’ contention that the authorized repair facilities were represented to be Defendant’s agents for purposes of repairs and to any evidence Defendant would offer to the contrary, and DENIED IN PART as to specific statements that were not identified in Plaintiffs’ motion.

In their motion, Plaintiffs refer to evidence they will offer to prove Defendant’s written representations that its authorized repair facilities will act on their behalf to service and repair the subject vehicle, and Defendant has offered no opposition to this motion.  It appears to the Court, therefore, that Defendants concede an agency relationship in the context of maintenance and repair work done by its authorized repair facilities, and that this is the specific context from which Plaintiff seeks to extract statements by employees of those facilities and offer them as evidence against Defendant.  In general, the Court agrees with Plaintiff that such statements should be considered party admissions, subject to presentation of additional evidence about the basis for Plaintiffs’ contention that the authorized repair facilities were represented to be Defendant’s agents for purposes of repairs, as well as any evidence Defendant would offer to the contrary.  That said, the question remains whether specific statements made fall within the scope of the alleged agency.  Because the Court cannot evaluate this issue unless specific statements are offered by Plaintiffs, the Court must grant the motion as to the general agency proposition advanced (subject to the presentation of corroborative evidence) and deny it as to any specific but as yet unidentified oral or written statements to be offered for admission.

PLAINTIFF’S MIL # 9:  seeking an order prohibiting argument or testimony Defendant’s §998 statutory offer to compromise. 

TENTATIVE RULING:  GRANTED, without opposition(See Code Civ. Proc. § 998(b)(2).)

DEFENDANT’S MIL # 11:   seeking to exclude any evidence or argument regarding concerns with the vehicle that were presented for one repair attempt.        

TENTATIVE RULING:  DENIED. 

Defendant’s moving papers request exclusion of problems that were repaired after one repair effort. In its supplemental motion, filed recently, Defendant urges the Court to exclude any repair orders that are unrelated to the three nonconformities that impaired use, safety and/or value according to Plaintiff’s expert, as well as any problems that were repaired within a reasonable number of attempts.   

With respect to the first type of evidence – as to concerns that were repaired after one repair opportunity, the Court finds first that there could be no exclusion of such evidence under Silvio v. Ford Motor Co. (2003) 109 Cal.App.4th 1205, on which Defendant relies, for Plaintiffs’ claim under Civil Code §1793.2(b), because liability under that provision is not dictated by the number of repair attempts but by the failure to repair a vehicle within 30 days of its presentation for repair.  Because the parties do not highlight precisely what evidence would be offered to support this claim and, thus, could not be excluded based on Defendant’s argument, the Court cannot make a wholesale exclusion order as requested by Defendant.  

Moreover, the Court concludes that Defendant’s reliance on Silvio is misplaced even with respect to Plaintiff’s claim under Civil Code § 1793.2(d)(2).  In Silvio, the consumer presented his car for repair only once and, when the problem persisted, demanded a repurchase.  Based on this factual scenario, the Court of Appeal held that the consumer had not stated a claim under Civil Code § 1793.2(d), because that statute offers remedies where the car manufacturer is “unable to service or repair a new motor vehicle . . . to conform to the applicable express warranties after a reasonable number of attempts.”  (Civ. Code § 1793.2(d)(2).)  Construing the statutory language referring to “a reasonable number of attempts,” the Court noted that “attempts” is plural, thus requiring that more than one repair opportunity was necessary to state a claim.  (Silvio, at pp. 1208-1209.)  Contrary to Defendant’s suggestion, the Silvio court did not rule that there must be multiple repair opportunities for the same vehicle problem.  Given the single repair visit in Silvio, the situation posed by Plaintiffs’ experience, where they presented their vehicle for repair of a number of problems on multiple occasions, was not even considered in that case.

What is more, the Court agrees with Plaintiffs that the question of whether the underlying defects confronted by Plaintiffs were related to one another or stemmed from a single systemic failing is a factual question to be determined by the jury based on the entire repair record for Plaintiffs’ vehicle, their testimony about the nature of the defects they experienced and reported, expert testimony by both sides’ designated experts, and other materials that might inform the jury’s deliberations.  It would be improper, if not impossible, for the Court to exclude certain repair visits as unrelated to others based solely on a review of the language included in the repair orders.  Such a ruling would assume the truth of all statements in those orders and necessarily negate any contrary evidence Plaintiffs might offer about what complaints they had and reported to the Honda mechanics.  Moreover, the jury could conclude from the evidence at trial that Plaintiffs’ vehicle was plagued with three or more constellations of related nonconformities, including those resident in the vehicle’s engine cooling, electrical, drivetrain and braking systems, and that Defendant failed to repair these defects even after four or five repair opportunities.

Nor does the Court accept Defendant’s contention that certain evidence should be excluded based on Defendant’s assessment that all existing problems that were covered under the warranty were repaired every time the vehicle was brought in for service.  Plaintiffs are entitled to contest the conclusions of Defendant’s mechanics during an individual repair visit that the underlying problem had been remedied by proving the defects continued or resurfaced after each repair visit. In Robertson v. Fleetwood Travel Trailers of California, Inc. (2006) 144 Cal.App.4th 785, 801, the Court of Appeal held that an incomplete repair of a covered product is not sufficient for a manufacturer to meet its obligations under Song-Beverly. Specifically, the Court of Appeal found that a manufacturer’s repair of a leak in an RV’s plumbing apparatus did not satisfy the manufacturer’s Song-Beverly obligations, because the repair effort did not remedy the water damage caused by the leak itself. (Id.) Thus, the product was not brought into conformity until all aspects of the “nonconformity” had been cured. (Id.) Further, the Third District stated in Donlen v. Ford Motor Co. (2013) 217 Cal.App.4th 138, 149, that evidence that a problem with a vehicle was fixed for a period of time but reappeared at a later date is relevant to a determination of whether the fundamental problem in the vehicle was ever resolved. Taken together, these rulings suggest that a defective vehicle remains nonconforming under the warranty, despite multiple attempts to repair the vehicle, until the defect is conclusively repaired.  Plaintiffs are entitled to offer evidence to demonstrate that their vehicle manifested this kind of recurring nonconformity. 

The Court also credits Plaintiff’s argument that she need not demonstrate more than one repair attempt to succeed under § 1793.2(d)(2).  The current standard established in the case law is that there must be more than one opportunity to repair the vehicle (so two is enough to press a claim), and that the jury must make the decision whether the number of repair opportunities given to the manufacturer under the circumstances was reasonable.  (Robertson v. Fleetwood Travel, supra, at p. 799.) 

Finally, the Court notes that a duty to repurchase or reimburse under section 1793.2(d)(2) is triggered by the manufacturer’s inability “to service or repair a new motor vehicle, as that term is defined in paragraph (2) of subdivision (e) of Section 1793.22, to conform to the applicable express warranties after a reasonable number of attempts.” (Emphasis added.)  While Song-Beverly refers to the need to correct a “non-conformity” in other parts of the statute, the key provision defining a claim under §1793.2(d)(2) does not state that here must be a reasonable number of attempts to remedy each nonconformity, as Defendant interprets the statute, but rather that the entire vehicle must be made to conform to warranties after a reasonable number of attempts.  While the issue is not specifically addressed in the appellate cases cited by the parties, many courts describe the question as one involving the repair of the entire vehicle, not remedying a particular nonconformity, within a reasonable number of repair opportunities.  (E.g., Oregel v. American Isuzu Motors, Inc. (2001) 90 Cal. App. 4th 1094, 1103-1104; Silvio, supra, at p. 1208.)