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Duncan v. Nissan North America, Inc.

United States District Court for the District of Massachusetts
305 F. Supp.3d 311 (2018)


Facts

Sarah Duncan and others (plaintiffs) brought a class action against Nissan North America, Inc. (defendant) based on a defective component in Nissan’s cars. According to a mechanic, the component was supposed to last the lifetime of the car but was made of plastic that wore away over time. The defect allegedly caused expensive engine damage and posed a possible safety hazard. The complaint alleged Nissan knew about the defect and disclosed it to dealerships in technical-repair bulletins but concealed it from consumers and set warranty limits that expired before the defect became apparent. The warranty covered 36 months or 36,000 miles for “repairs needed to correct defects in the materials.” Nissan moved to dismiss the breach-of-warranty claims on the ground that all the repairs occurred after that warranty period expired. The claimants countered that the component malfunctioned during the warranty period, even though the repairs occurred later, and that the warranty limits were unconscionable and unenforceable under the Uniform Commercial Code (UCC).

Rule of Law

Issue

Holding and Reasoning (Casper, J.)

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