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Ryan v. American Honda Motor Corporation

376 N.J. Super. 185, 869 A.2d 945 (App. Div. 2005)

AUTOMOBILES; WARRANTIES—Under the Magnuson-Moss Warranty Federal Trade Commission Improvement Act, a vehicle manufacturer qualifies as a supplier, and more importantly, the lessee of a vehicle from that manufacturer qualifies as a buyer.

A lessee sued a vehicle manufacturer for breach of warranty after the car he leased broke down after being driven roughly 22,000 miles within the first fifteen months of the lease term. The manufacturer claimed the lessee had no cause of action since only purchasers, and not lessees, have any recourse in the pertinent Magnuson-Moss Warranty Federal Trade Commission Improvement Act (Act). The Appellate Division disagreed.

The Court held that the Act applies to warranties made to lessees since – per the provisions of the Act—an “implied warranty” can be the product of any sale of consumer merchandise by a supplier like the manufacturer—regardless of the buyer’s characteristics. The Court also held that the manufacturer here qualified as a “supplier” under the Act and that the term “buyer” also applies to lessees. The Court furthermore held that a different interpretation of the Act would defeat its purpose to protect society against deceptive, misleading, and false promises by suppliers of consumer merchandise.

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