Motley v. Jaguar Land Rover North America LLC
When ruling whether to grant class action certification, courts may consider whether the plaintiffs meet the requirements of numerosity, commonality, typicality and adequacy of representation for a class-action suit. The plaintiffs sued Jaguar Land Rover North America, on behalf of themselves and similarly situated individuals, alleging that Land Rover LR3s produced in 2005 and 2006 had an alignment defect that resulted in premature tire wear. The plaintiffs requested class certification of their claims that Land Rover breached the warranty and violated the Connecticut Unfair Trade Practices Act, the Connecticut Products Liability Act, the Automobile Warranty Adjustment Act and the Rhode Island Deceptive Trade Practice Act. Allegations that there are hundreds of individuals who purchased or leased the LR3 Land Rovers were sufficient to meet the requirement of numerosity. The court rejected Land Rover's argument that dissimilarities in issues and individual proof make the plaintiffs unable to meet the commonality requirement. All prospective class members owned or leased the same model of motor vehicle and allege the same defect and the same warranties. "The question and answer as to whether there was a factory defect on all of the [plaintiffs'] Land Rover vehicles, and if Land Rover was bound under the warranty to repair," wrote the court, "is common to all in the class." Although individual claims can vary, as a result of the dates of purchase or lease and costs of repair, the plaintiffs' claims are typical of those of the putative class, because they arise from the same product and alleged defect. Plaintiffs' counsel is litigating an action with the same issues in California and is adequate to represent the putative class. Common issues of law and fact predominate over individual issues. A class action provides a superior method to resolve the dispute. The court granted the plaintiffs' motion to certify a class action.