Maneotis v. FCA US, LLC

Colorado resident Dedra Maneotis (plaintiff) owned a Jeep Grand Cherokee designed and manufactured by Michigan-based FCA US, LLC (FCA) (defendant). One day, Maneotis pulled up a hill onto her driveway and put the vehicle in park. As she stepped out of the vehicle, it began to roll backward. The vehicle eventually rolled over Maneotis’s leg and spun on it, causing serious injuries. Police determined that the vehicle’s electronic shifting system had not been in park as Maneotis thought. Maneotis sued FCA in a federal district court in Michigan. She asserted various claims based on the gearshifts in Grand Cherokees being dangerously defective because they did not provide sufficient visual and tactile feedback to allow drivers to know whether a vehicle was in the intended gear. Discovery revealed that FCA was aware of the issue and had in fact negotiated to license safer gearshifts for Grand Cherokees but then reversed course when it deemed the licensing costs too high. The parties agreed that Maneotis’s claims were governed by Colorado law. However, when Maneotis subsequently sought leave to file an amended complaint to add a punitive-damages claim under Colorado law, a choice-of-law dispute arose. FCA objected to the amended complaint, arguing that it was futile because Michigan law governed that issue and it barred punitive-damages awards. Alternatively, FCA argued that even if Colorado law governed the issue, the amended complaint was still futile because the alleged facts did not demonstrate the malicious intent necessary for punitive damages under Colorado law. The district court considered the choice-of-law issue.