In re Toyota Hybrid Brake Litig.
| Decision Date | 21 October 2020 |
| Docket Number | Consolidated Case No. 4:20-CV-127 |
| Parties | IN RE: TOYOTA HYBRID BRAKE LITIGATION |
| Court | U.S. District Court — Eastern District of Texas |
MEMORANDUM OPINION & ORDER
Pending before the Court is Proposed Intervenor's Motion to Intervene for the Limited Purpose of Moving (1) to Dismiss, Stay, or Transfer and (2) for Reconsideration of Order Appointing Counsel (Dkt. #20). Having considered the relevant pleadings, the Court finds that the Motion should be denied.
This litigation began on January 22, 2020, in the United States District Court for the Central District of California. Jason Medeiros ("Medeiros") and Nancy Bennett-Hauser ("Bennett-Hauser") filed a class-action complaint against Defendants Toyota Motor Corporation ("TMC") and Toyota Motor Sales, U.S.A, Inc. ("TMS"). Compl., Medeiros v. Toyota Motor Corp., No. 2:20-cv-683-RGK-MAA (C.D. Cal. Jan. 22, 2020), ECF No. 1. In their complaint, Medeiros and Bennett-Hauser alleged eight causes of action against the Defendants, all of which centered around allegations of "breach of the manufacturer's warranty and for unfair or deceptive acts or practices pertaining to [the] design and manufacture" of the "Class Vehicles"—the "2010-2015 Prius and Prius PHV, 2012-2015 Prius V, 2012-2014 Camry Hybrid, and 2013-2015 Avalon Hybrid." Id. at 1, ¶ 1. Specifically, plaintiffs alleged that Defendants "designed and/or manufactured defective break booster pump assemblies in the Class Vehicles, which cause[d] the Class Vehicles' braking systems to fail." Id., ¶ 3. The alleged causes of action were as follows: (1) violations of the Magnuson-Moss Warranty Act, 15 U.S.C. § 2301 et seq.; (2) violations of the Consumers Legal Remedies Act, CAL. CIV. CODE § 1750 et seq.; (3) violations of the California Unfair Competition Law, CAL. BUS. & PROF. CODE § 17200; (4) violation of California false advertising law, CAL. BUS. & PROF. CODE § 17500 et seq.; (5) breach of express warranty based on California law; (6) breach of implied warranty based on California law; (7) common law fraudulent concealment based on California law; and (8) breach of implied warranty under the Song-Beverly Act, CAL. CIV. CODE §§ 1791.1, 1792 et seq. See Compl. 118-28, ¶¶ 90-155, Medeiros v. Toyota Motor Corp., No. 2:20-cv-683-RGK-MAA (C.D. Cal. Jan. 22, 2020), ECF No. 1.
One month later, Laura Turner ("Turner") and Glenn Alcaraz ("Alcaraz") filed a similar class action against TMC and TMS in the United States District Court for the Central District of California. Compl., Turner v. Toyota Motor Corp., No. 5:20-cv-320-PA-SHK (C.D. Cal. Feb. 18, 2020), ECF No. 1. In their complaint, Turner and Alcaraz alleged ten causes of action against the Defendants, all of which pertained to allegations of "breach of warranty and for unfair and deceptive acts or practices arising from [Defendants'] design, manufacture, and sale" of the "Defective Class Vehicles"—the "2010-2015 Prius and Prius PHV, 2012-2015 Prius V, 2012-2015 Avalon Camry Hybrid, and 2013-2015 Avalon Hybrid vehicles." Id. at 1, ¶ 1. In particular, Turner and Alcaraz allege that the Defective Class Vehicles were "plagued by and possess[ed] a dangerous design and/or manufacturing defect in their braking systems . . . , which defect is more specifically associated with the brake booster pump assemblies with master cylinder in the Defective Class Vehicles and cause[d] said vehicles' braking systems to fail." Id., ¶ 2. The Turner/Alcaraz complaint, in addition to the same causes of action pleaded in the Medeiros/Bennett-Hauser complaint, alleged two additional causes of action: (1) unjust enrichment based on California law; and (2) violations of the Washington Consumer ProtectionAct, WASH. REV. CODE § 19.86.020. See Compl. 33-34, ¶¶ 142-46; 35-36, ¶¶ 154-60, Turner v. Toyota Motor Corp., No. 5:20-cv-320-PA-SHK (C.D. Cal. Feb. 18, 2020), ECF No. 1.
Three days later, Mariano Alaniz ("Alaniz"), the movant and would-be intervenor in the action now before the Court, filed a class-action lawsuit against TMC and TMS in the United States District Court for the Northern District of California. Compl., Alaniz v. Toyota Motor Corp., No. 4:20-cv-01351-JST (N.D. Cal. Feb. 21, 2020), ECF No. 1. In his complaint, Alaniz alleges eight causes of action against the Defendants, all centered on allegations of "a design defect in the braking system" of the "Class Vehicles"—the "2010-2015 Prius and Prius PHV, 2012-2015 Prius V, 2012-2014 Camry Hybrid, and 2013-2015 Avalon Hybrid." Id. at 2, ¶ 1. Specifically, Alaniz alleges that the Class Vehicles "contain defective brake booster pump assemblies," defects which will allegedly "impede[] the Class Vehicles' ability to stop, posing a severe and material safety hazard," and "cause owners of Class Vehicles to incur costly repairs while also reducing the resale and intrinsic value of the Class Vehicles." Id., ¶ 2. The majority of the claims for relief Alaniz pleads are also found in either the Medeiros/Bennett-Hauser complaint or the Turner/Alcaraz complaint. Alaniz's complaint differs in two respects: (1) the cause of action for fraud based on California law is expanded to fraud generally as opposed to fraudulent concealment; and (2) his pleadings include a cause of action for negligent misrepresentation. See id. at 40-43, ¶¶ 66-83.
On February 24, 2020, Chong Eun, Stephanie Owens, Enrique Pabon, Bryan Feinberg, David Siegal, Gregory Vasquez, Madeline Vasquez, and Lois Felts ("Original Eastern District Plaintiffs") filed a class action suit against TMC and TMS in the United States District Court for the Eastern District of Texas (Dkt. #1). In their complaint, Original Eastern District Plaintiffs alleged thirty different causes of action against the Defendants, focusing on the alleged "breach of the manufacturer's warranty and for unfair or deceptive acts or practices pertaining to[Defendants'] design and manufacture" of the "Class Vehicles," which included the "2010-2015 Prius and Prius PHV, 2012-2015 Prius V, 2012-2014 Camry Hybrid, and 2013-2015 Avalon Hybrid" (Dkt. #1 at p. 1). In particular, Original Eastern District Plaintiffs allege that the Class Vehicles "contain a significant design and/or manufacturing defect in their braking systems," "which cause their braking systems to fail" and "directly affects [Original Eastern District] Plaintiffs' use, enjoyment, safety, and value of the Class Vehicles" (Dkt. #1 at p. 2). In addition to alleging the same causes of action as those in the Medeiros/Bennett-Hauser complaint, the Turner/Alcaraz complaint, and the Alaniz complaint, the Original Eastern District Plaintiffs' complaint also alleges similar causes of action under the state laws of Colorado, Florida, New Jersey, and North Carolina (see Dkt. #1 at pp. 124-65).1
Then on March 11, 2020, Willie Rose ("Rose") and Jeffrey Warner Rasco ("Rasco") filed their own class-action complaint against TMC and TMS in the United States District Court for the Eastern District of Texas. Compl., Rose v. Toyota Motor Corp., No. 4:20-cv-00199-ALM (E.D. Tex. Mar. 11, 2020), ECF No. 1. In the complaint, Rose and Rasco alleged ten causes of action against the Defendants, all based on allegations of "breach of warranty and for unfair and deceptive acts or practices arising from Toyota's design, manufacture, and sale" of the "Defective Class Vehicles"—the "2010-2015 Prius and Prius PHV, 2012-2015 Prius V, 2012-2015 Avalon Camry Hybrid, and 2013-2015 Avalon Hybrid." Id. at 2. Rose and Rasco specifically alleged that the Defective Class Vehicles were "plagued by and possess[ed] a dangerous design and/ormanufacturing defect in their braking systems," "directly, materially, and adversely affect[ing] [Rose's, Rasco's] and Class Members' use and enjoyment of the Defective Class Vehicles, their safety, and their value." Id. The majority of the claims for relief Rose and Rasco pleaded are also found in the complaints detailed by the Court above. The Rose/Rasco complaint included two causes of action not previously alleged against Defendants: (1) breach of implied warranty under Texas law, TEX. BUS. & COM. CODE § 2.314; and (2) breach of express warranties, TEX. BUS. & COM. CODE § 2.313.
Next, on March 20, 2020, the two then-pending cases in the Central District of California—the Medeiros/Bennett-Hauser action and the Turner/Alcaraz action—were voluntary dismissed without prejudice in accordance with Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure. See Notice of Voluntary Dismissal, Medeiros v. Toyota Motor Corp., No. 2:20-cv-683-RGK-MAA (C.D. Cal. Mar. 20, 2020), ECF No. 14; Notice of Voluntary Dismissal, Turner v. Toyota Motor Corp., No. 5:20-cv-320-PA-SHK (C.D. Cal. Mar. 20, 2020), ECF No. 22. Importantly, the litigants in these now-dismissed cases reappeared later—in the action currently before the Court (see Dkt. #28).
Three days after the voluntary dismissals, Yvette Winia ("Winia"), Raul Rivera ("R. Rivera"), Cristina Rivera ("C. Rivera"), and Kamran Khan ("Khan") filed a class action against TMC and TMS in the United States District Court for the Eastern District of Texas. Compl., Winia v. Toyota Motor Corp., No. 4:20-cv-00240-ALM (E.D. Tex. Mar. 23, 2020), ECF No. 1. This complaint alleged six causes of action against the Defendants, focusing on allegations that the "Class Vehicles"—the "2010-2015 Prius or Prius PHV, 2012-2015 Prius V, 2012-2014 Camry Hybrid, or 2013-2015 Avalon Hybrid"—"contain[ed] a significant defect in their braking systems and pose[d] an immediate and significant safety hazard to vehicle operators and the public." Id.at 2. In particular, these plaintiffs alleged that the defect in the braking systems of the Class Vehicles was "dangerous and life threatening and adversely affect[ed] [the plaintiffs'] use, enjoyment, safety, and value of the Class Vehicles." Id. A number of the claims for relief Winia, R. Rivera, C. Rivera, and Khan plead are also found in the complaints previously...
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