Abraham v. Volkswagen of America, Inc.

795 F.2d 238 (1986)

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Abraham v. Volkswagen of America, Inc.

United States Court of Appeals for the Second Circuit
795 F.2d 238 (1986)

Facts

Irwin Abraham and a large number of other individuals (collectively, the owners) (plaintiffs) owned Volkswagen Rabbits manufactured by Volkswagen of America (VWOA) (defendant) from 1975 to 1979. The owners brought a class action in federal district court against VWOA under the Magnuson-Moss Act, alleging a variety of defects in the oil systems of their vehicles. VWOA moved to sever all individual claims on the ground of improper joinder and to then dismiss each severed claim for lack of subject-matter jurisdiction. The district court held that because of the variety of defects alleged and the disparities in timing of when problems occurred, the claims did not satisfy the same-transaction-or-occurrence requirement needed for permissive joinder under Federal Rule of Civil Procedure 20 (Rule 20). The district court granted VWOA’s motion, severed all claims, and dismissed the action. The owners moved for reconsideration on the issue of joinder and for leave to amend their complaint in order to make clear that all claims were alleging the same defect—a valve-stem seal made of a defective material that resulted in the seal hardening and breaking with time. The district court allowed the owners to amend their complaint but again dismissed the action, citing its previously stated reasons. The owners appealed.

Rule of Law

Issue

Holding and Reasoning (Winter, J.)

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