August 24, 2019

Tenth Circuit: Proposed Class of Defective Car Owners Denied as Prudentially Moot

The Tenth Circuit Court of Appeals published its opinion in Winzler v. Toyota Motor Sales U.S.A., Inc. on Monday, June 18, 2012.

The Tenth Circuit vacated the district court’s decision. Petitioner “brought state law claims against Toyota on behalf of a proposed nationwide class of 2006 Toyota Corolla and Toyota Corolla Matrix owners and lessees. She alleged that the cars harbored defective ‘Engine Control Modules’ (“ECMs”), making them prone to stall without warning. As relief, she asked for an order requiring Toyota to notify all relevant owners of the defect and then to create and coordinate an equitable fund to pay for repairs. . . . “Before addressing whether [Petitioner]’s class should be certified, the district court held her complaint failed to state a claim and dismissed it. . . . And then, just as [Petitioner] began her appeal, Toyota announced a nationwide recall of 2005-2008 Toyota Corolla and Corolla Matrix cars to fix their ECMs. The ongoing recall is taking place under the auspices of the National Traffic and Motor Vehicle Safety Act. That statute obliges Toyota to notify owners of the defect and repair or replace any faulty parts at no cost. And the whole process is overseen by the National Highway Transportation Safety Administration (“NHTSA”), an agency of the Department of Transportation that can issue stiff fines if the company fails to carry out the recall to its satisfaction. Arguing that these statutory and regulatory processes promise [Petitioner] exactly the relief sought in her complaint, Toyota has asked this court to find that events have overtaken her suit and rendered it moot.”

“Because prudential mootness is arguably the narrowest of the many bases Toyota has suggested for dismissal, and because it is sufficient to that task, . . . [the Court granted] the motion to supplement the record and . . . following [the] general practice when finding a case moot (prudentially or otherwise) on appeal,” the Court vacated the district court’s judgment and remanded with instructions to dismiss the case as moot.

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