Maronyan v. Toyota Motor Sales

Summarized by:

  • Court: 9th Circuit Court of Appeals Archives
  • Area(s) of Law: Civil Procedure
  • Date Filed: 09-20-2011
  • Case #: 09-56949
  • Judge(s)/Court Below: Circuit Judge Reinhardt for the Court; Circuit Judge Nelson; dissent by Circuit Judge N. R. Smith
  • Full Text Opinion

The Magnuson-Moss Warranty Act’s exhaustion requirement does not use sweeping and direct language demonstrating clear congressional intent to mandate loss of subject matter jurisdiction.

Maronyan’s new car developed mechanical problems during the warranty period. Toyota failed to repair it to her satisfaction, Mariam Maronyan brought suit against Toyota Motor Sales, U.S.A., Inc. Maronyan alleged breach of warranty under the Magnuson-Moss Warranty Act (MMWA), in addition to several California state claims. The district court granted Toyota’s motion to dismiss for lack of subject matter jurisdiction on the grounds that Maronyan did not pursue her claims through the California Dispute Settlement Program (CPSD) before filing suit in civil court per Toyota’s warranty terms. In examining the language of the MMWA, the Ninth Circuit concluded the statute’s plain language reflects that the dispute settlement procedures are not a jurisdictional bar, but a prudential exhaustion requirement. The Ninth Circuit, in remanding the case for the district court to consider how to proceed, held § 2310(a)’s prerequisite that a “consumer may not commence a civil action unless he initially resorts to [an informal dispute settlement procedure]” is merely a codification of the MMWA’s exhaustion requirement and does not operate as a jurisdictional bar. REVERSED and REMANDED.

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