Stiles v. Kia Motors America, Inc. – Used Cars Are Covered Under the Lemon Law

In a recent landmark decision, the California Court of Appeal for the Second District held in favor of plaintiffs Brandi Stiles and Abel Gorgita against Kia Motors America, Inc., reinforcing critical consumer protections under the Song-Beverly Consumer Warranty Act (commonly known as the “Lemon Law”). This case highlights the significant legal implications for both consumers and legal practitioners dealing with warranty disputes over defective vehicles purchased used with the manufacturer’s new car warranty still in effect.

Case Summary

The case involved Brandi Stiles and Abel Gorgita, who purchased a 2011 Kia Optima in 2013. Despite the car still being covered by Kia’s original warranties, it exhibited numerous defects including issues with the transmission, electrical system, brakes, engine, suspension, and steering. When Kia failed to adequately repair these defects after several attempts, Stiles and Gorgita sought relief under the Song-Beverly Act.

The trial court initially sided with Kia, sustaining their demurrer and ruling that the remedies under the Song-Beverly Act applied only to new vehicles, and not to previously owned vehicles with unexpired warranties. However, upon appeal, this decision was reversed. The appellate court held that a vehicle purchased with the manufacturer’s new car warranty still in effect qualifies as a “new motor vehicle” under the Act, thus entitling the plaintiffs to the Act’s replace or refund remedies.

Implications of the Decision

For Consumers

This decision is a significant victory for consumers, particularly those who purchase used vehicles that are still under the original manufacturer’s warranty. The ruling ensures that these consumers are protected under the Song-Beverly Act and are entitled to the same remedies as those who purchase new vehicles directly from manufacturers or authorized dealers.

In the words of the Court:

“Stiles’s car in precisely meeting the definition as a ‘motor vehicle sold with a manufacturer’s new car warranty’ is a new motor vehicle as defined by the statute.”

This interpretation prevents manufacturers from evading their warranty obligations simply because a vehicle has changed hands.

For Legal Professionals

For attorneys, this ruling underscores the importance of understanding the full scope of consumer protection laws and the specific definitions contained within those laws. The appellate court’s reliance on a plain reading of the statute and its legislative history highlights a critical strategy for legal arguments in similar cases.

Knight Law Group: Advocates for Consumer Rights

Knight Law Group played a pivotal role in achieving this favorable outcome for Stiles and Gorgita. The firm’s expertise and dedication to consumer rights were instrumental in overturning the trial court’s decision. Their meticulous legal strategy and thorough understanding of the Song-Beverly Act were key factors in the appellate court’s ruling.

Key Quotes from the Opinion

1. On the plaintiff’s allegation:

“Thus Stiles is entitled to the replace or refund remedy of section 1793.2, subdivision (d)(2) if the car she purchased was a “motor vehicle sold with a manufacturer’s new car warranty.” (§ 1793.22, subd. (e)(2).) Stiles so alleges. That should be the end of the discussion.”

2. On the inclusion of used cars under the definition of new motor vehicles:

“[T]he phrase “or other motor vehicle sold with a manufacturer’s new car warranty” appears under the definition of a new motor vehicle. (§ 1793.22, subd. (e)(2).) That is why we conclude Stiles’s car, in precisely meeting the definition as a “motor vehicle sold with a manufacturer’s new car warranty,” is a new motor vehicle as defined by the statute. […] The statute contains no such limitation as vehicles that have never been previously sold to a consumer and come with full express warranties.”

3. On legal precedent for inclusion of used cars under the law:

“Jensen, supra, 35 Cal.App.4th 112, 41 Cal.Rptr.2d 295, was properly decided. Jensen involved a previously owned vehicle that was subject to the manufacturer’s new car warranty. The Court of Appeal held that the vehicle qualified as a new motor vehicle as defined in section 1793.22, subdivision (e)(2). In so holding, the court concluded that the statute was reasonably free from ambiguity, and relied on the rule of statutory construction, that we must examine the language of the statute, giving the words their ordinary meaning, and if the words are reasonably free from ambiguity, the language controls. […] We, like Jensen […] look to the plain words of the statute. If any legislative history is required, its most salient feature is that more than 30 years after section 1793.22 was enacted and almost 30 years after Jensen was decided, the Legislature has not amended the definition of “new motor vehicle” in section 1793.22. And neither will we.”

Conclusion

The appellate court’s decision in Stiles v. Kia Motors America, Inc. reinforces critical protections for consumers under the Song-Beverly Act. It ensures that manufacturers honor their warranty commitments, regardless of whether the vehicle is sold new or as a used car with an unexpired warranty. For legal professionals, this case serves as an important precedent and a reminder of the power of clear statutory interpretation.

Knight Law Group’s successful representation in this case highlights their commitment to advocating for consumer rights and holding manufacturers accountable. This ruling is a win for all consumers who might find themselves dealing with a lemon and ensures that they have the legal backing to seek the remedies they deserve.


For more information or to seek legal advice on similar matters, please contact Knight Law Group.

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