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Reid v. Leson Chevrolet Co., Inc.

Citations: 542 So. 2d 673; 1989 La. App. LEXIS 672; 1989 WL 36956Docket: 88-CA-823

Court: Louisiana Court of Appeal; April 12, 1989; Louisiana; State Appellate Court

Narrative Opinion Summary

In the case, the plaintiff, having purchased a 1984 Chevrolet Corvette from Leson Chevrolet, experienced numerous issues with the vehicle, including a malfunctioning anti-theft device that resulted in a steering lock while driving. Despite returning the vehicle multiple times for repairs, the issues persisted. The plaintiff filed a lawsuit against both Leson and General Motors (GM) for redhibition and personal injuries sustained from the steering incident. The jury ruled in favor of the plaintiff on the claim of redhibition, finding that the vehicle had defects rendering it significantly inconvenient. Leson and GM contested the ruling, arguing that the issues did not constitute redhibitory defects and that they had not been provided a reasonable opportunity to repair the vehicle. The court affirmed the jury's decision, emphasizing that the Reids had returned the vehicle for repairs on multiple occasions, and the defects were not satisfactorily addressed. The ruling highlighted that multiple minor defects could collectively amount to a significant inconvenience, justifying the rescission of the sale under Louisiana law. The appellants were ordered to bear the costs of the appeal equally.

Legal Issues Addressed

Existence of Redhibitory Defects

Application: The jury found that the vehicle had redhibitory defects based on multiple issues, including a malfunctioning anti-theft device and steering lock.

Reasoning: The existence of a redhibitory defect and the concept of reasonable opportunity to repair are matters for a judge or jury to decide.

Manufacturer's Knowledge of Defects

Application: GM, as the manufacturer, was presumed to have knowledge of the defects, affecting their liability in the redhibition claim.

Reasoning: However, this requirement does not apply to sellers acting in bad faith or manufacturers, who are presumed to know defects.

Minor Defects and Collective Action

Application: The court considered whether multiple minor defects could collectively justify rescission of the sale under redhibition principles.

Reasoning: Minor defects do not qualify for redhibitory action, but multiple minor defects may collectively justify such action.

Redhibition under Louisiana Law

Application: The case involved a claim for redhibition, where the plaintiff sought rescission of the sale of a vehicle due to defects that rendered it significantly inconvenient.

Reasoning: The plaintiff failed to demonstrate entitlement to rescission of the sale under Louisiana's redhibition law, which allows avoidance of a sale due to a hidden defect that renders the item useless or significantly inconvenient.

Seller's Opportunity to Repair

Application: The court evaluated whether the seller had a reasonable opportunity to repair defects before the plaintiff sought rescission of the sale.

Reasoning: Before recovering the purchase price, the buyer must return the item to the seller, allowing the seller a reasonable opportunity to repair the defect.