Razor v. Hyundai Motor America

In August 2001, Shante Razor (plaintiff) purchased a new sedan manufactured by Hyundai Motor America (Hyundai) (defendant). Razor bought the car at a Buick dealership, Gartner. The car came with a limited manufacturer’s warranty, allowing for repair or replacement of defective parts for 60 months or 60,000 miles, whichever came sooner. In September 2001, while the car was under warranty, Razor was unable to start her car and had to have it towed to Gartner. Gartner did not find anything wrong, and Razor missed a day of work. In October 2001, the car had problems starting. Gartner replaced the starter and provided Razor with a loaner car for two days. Later in October, Razor had to have her car towed to Gartner again. Over three days, technicians replaced a shorted part. A little over a week later, Razor brought the car to Gartner once more, complaining that it would not start. In November, the car had problems starting yet again. At that point, Razor “just broke down”; she had missed or been late to work multiple times and had lost time from waiting for tows or rides. To make matters worse, Gartner’s service manager indicated that Razor was causing the problem. Razor sued Hyundai under the Magnuson-Moss Warranty Act (MMWA), asserting breach of written warranty and implied warranty of merchantability, among other claims. Razor sought damages, including consequential damages, and Razor was the sole witness in her case. The jury awarded Razor $5,000 on her warranty claims, $3,000 for aggravation and inconvenience, and $500 for loss of use. The trial court additionally awarded attorney’s fees and costs. Hyundai appealed, challenging Razor’s ability to obtain consequential damages from Hyundai.