The Ninth Circuit partially reversed an order certifying multiple state‑law classes in litigation alleging that certain Ford Super Duty trucks suffer from a steering defect. See Lessin et al. v. Ford Motor Co., No. 25‑2211 (9th Cir. Feb. 11, 2026). While the Ninth Circuit affirmed parts of the class certification order, it held that the district court abused its discretion by certifying several classes without adequately evaluating whether plaintiffs could demonstrate the alleged defect with common evidence.

Plaintiffs allege that Ford F‑250 and F‑350 trucks with model years spanning from 2005 to 2019 contain a steering defect known as the “shimmy,” which can cause severe shaking and oscillation of the steering wheel. See Lessin v. Ford Motor Co., 756 F. Supp. 3d 885, 903–04 (S.D. Cal. 2024). The district court certified multiple state subclasses spanning four distinct design platforms, concluding that common questions predominated because plaintiffs alleged a design defect present at the time of sale. Id. at 934–52. The district court relied on Wolin v. Jaguar Land Rover North America, LLC, 617 F.3d 1168 (9th Cir. 2010), to conclude that proof of defect manifestation was not required at the class‑certification stage. See Lessin, 756 F. Supp. 3d at 947–48.

Ford appealed, arguing that the alleged defect manifested at different rates across different models of its trucks, meaning that plaintiffs needed to show that common evidence could demonstrate the defect. Lessin, No. 25-2211 at 3–4.The Ninth Circuit agreed, finding that the district court misread Wolin. The Ninth Circuit noted that Wolin involved a single platform and limited model years. Therefore, the court’s conclusion that manifestation evidence was irrelevant to the predominance analysis has no application where, as in Lessin, certified classes span multiple platforms and nearly 20 model years. Id. at 6. Accordingly, the court reversed the certification order in part and remanded for further analysis.

The ruling also held that the district court erred by allowing plaintiffs to rely on generalized evidence to show Ford’s presale knowledge of the alleged defect across vehicle models. As the Ninth Circuit explained, plaintiffs could not rely on evidence developed after certain models were sold to establish Ford’s knowledge at the time those earlier vehicles entered the market. Id. at 10.

The decision underscores that defendants opposing class certification in complex product‑defect cases should develop and present evidence showing meaningful variation across years, platforms, or designs, particularly where plaintiffs allege a single, uniform defect. More broadly, the Ninth Circuit’s analysis reinforces that courts must engage in a careful, evidence‑based predominance inquiry, particularly in cases involving various product models and/or an expansive proposed class.