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Jones v. Fleetwood Motor Homes

Citations: 127 F. Supp. 2d 958; 2000 U.S. Dist. LEXIS 17237; 2000 WL 1760767Docket: 98 C 3061

Court: District Court, N.D. Illinois; November 2, 2000; Federal District Court

Narrative Opinion Summary

The case involves a lawsuit initiated by the plaintiff against Fleetwood Motor Homes, Crystal Valley RV, Inc., and Ford Motor Company, alleging defects in a 1995 Pace Arrow motor home and inadequate repairs under the Magnuson-Moss Warranty Act. The claims included breach of written and implied warranties. The jury found in favor of Crystal Valley and Ford, but against Fleetwood, awarding damages for loss of use and aggravation. Fleetwood's post-trial motions, including for judgment as a matter of law, were denied by the court, which emphasized that the jury's verdict was supported by evidence. The court found that Fleetwood's warranty failed its essential purpose due to untimely and inadequate repairs, rendering its exclusion of consequential damages unenforceable. The plaintiff's request for refund and rescission was denied, as loss of use damages were considered an adequate remedy. Fleetwood's offer of judgment was insufficient under Rule 68 due to its ambiguity and failure to exceed the jury's verdict amount. The plaintiff was awarded attorney fees and costs, reflecting the time spent on the successful warranty claim, but without a multiplier. Crystal Valley was granted limited costs, while Fleetwood and Crystal Valley's requests for attorney fees were denied. The case underscores the application of consumer protection laws and the limitations on warranty disclaimers.

Legal Issues Addressed

Attorney Fees under Magnuson-Moss Warranty Act

Application: The plaintiff was awarded attorney fees, reflecting the actual time spent litigating the successful warranty claim against Fleetwood.

Reasoning: Plaintiff is awarded $22,837.88 in attorney fees and $615.12 in costs... The court found that a risk multiplier could be justified as it relates to actual time expended.

Failure of Warranty's Essential Purpose

Application: The jury found Fleetwood's warranty failed of its essential purpose due to inadequate and untimely repairs, allowing the plaintiff to claim damages for loss of use.

Reasoning: Fleetwood was found by the jury to have inadequately repaired or replaced parts within a reasonable number of attempts, resulting in the warranty failing of its essential purpose.

Limitations on Consequential Damages

Application: The court held that Fleetwood's exclusion of consequential damages was unenforceable because the warranty failed its essential purpose.

Reasoning: Due to the disparity in bargaining power and the warranty's purpose, the exclusion of consequential damages will not be enforced, allowing the plaintiff to claim damages for loss of use.

Magnuson-Moss Warranty Act - Breach of Warranty

Application: The plaintiff alleged that Fleetwood breached its written warranty by failing to repair defects in the motor home within a reasonable timeframe.

Reasoning: The case involved claims under the Magnuson-Moss Warranty Act, including breach of written warranty against Fleetwood...

Offer of Judgment and Rule 68

Application: Fleetwood's offer of judgment was deemed insufficient, as it lacked clarity and was not more favorable than the jury's verdict.

Reasoning: The offer's ambiguity undermines Fleetwood's claim for cost-shifting under Rule 68, as the judgment amount of $5,000 only pertains to Fleetwood, while the offer encompassed both Fleetwood and Crystal Valley without a clear breakdown of amounts from each defendant.

Standard for Judgment as a Matter of Law

Application: Fleetwood's motion for judgment as a matter of law was denied, as the evidence supported the jury's verdict in favor of the plaintiff.

Reasoning: Fleetwood filed a motion for judgment as a matter of law, arguing that: (1) repairs were made timely... The legal standard for post-trial motions requires evaluating whether the evidence supports the verdict when viewed favorably toward the nonmovant.