Another federal judge in the Eastern District of Michigan dismissed a putative class action against a vehicle manufacturer on prudential mootness grounds, holding that the manufacturer’s voluntary recall program mooted the plaintiffs’ claims. See Letson v. Ford Motor Co., 2024 WL 845844 (E.D. Mich. Feb. 28, 2024).

In August 2022, Ford identified cracked fuel injectors as a potential engine fire risk in some of its vehicles. To address the fire risk, Ford contacted the National Highway Traffic Safety Administration (NHTSA) and initiated a recall. As part of the recall program with NHTSA, Ford promised to provide free-of-charge two engine-related fixes that would reduce the fire risk of a cracked fuel injector.  It also promised a one-time repair of cracked fuel injectors over the useful life of the vehicles. The same month Ford informed vehicle owners about the recall, three plaintiffs filed a nationwide class-action lawsuit against Ford, claiming that they overpaid for their vehicles at the time of sale because the undisclosed defective fuel injectors diminished their vehicles’ values.

Relying on the prudential mootness doctrine, the court dismissed the case. The court noted that a case is prudentially moot when a different branch of the federal government steps in to provide the relief that a plaintiff seeks. In the court’s view, Ford’s recall program remediated plaintiffs’ injuries by addressing the fire risk from cracked fuel injectors without charge. The court also noted that NHTSA would oversee Ford’s recall program and could impose significant fines if Ford failed to carry out the recall effectively.

Plaintiffs argued that the recall did not truly remediate their injuries, but the court disagreed—Ford’s recall program offered to restore the plaintiffs’ vehicles to their pre-defect values, and thus eliminated their overpayment injuries. Plaintiffs also failed to establish that Ford’s recall program was ineffective. One plaintiff experienced an engine fire after undergoing Ford’s recall repair, but plaintiffs could not show that a cracked fuel injector caused the fire.

Letson joins a growing number of cases holding that a voluntary recall program overseen by a federal regulator moots a lawsuit based on the same defect. Manufacturers defending against class-action lawsuits in similar circumstances should therefore strongly consider raising a prudential mootness argument.