Christopher Grigorian

Christopher Grigorian

Foley & Lardner LLP

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NHTSA Announces Record Setting Civil Penalty in Consent Order With Chrysler

In 2014, NHTSA collected a record setting amount of civil penalties. For 2015, NHTSA may be on pace to exceed last year’s record. On July 26, 2015, NHTSA announced a $105 million civil penalty against FCA US LLC, the former...more

8/3/2015 - Auto Manufacturers Automobile Recall Automotive Industry Chrysler Civil Monetary Penalty Consent Order Manufacturing Defects Motor Vehicles NHTSA Public Safety

DOT Issues Scathing Internal Report of NHTSA’s Defect Investigation Processes

In the wake of GM’s ignition-switch, the Secretary of Transportation, Anthony R. Foxx, directed an investigation into NHTSA’s defect investigation policies and procedures. Specifically, Secretary Foxx requested that the U.S....more

6/30/2015 - Automobile Recall Automotive Industry Consumer Complaint System DOT Government Investigations NHTSA OIG Policies and Procedures

NHTSA Seeks to Push Beyond the “New Normal” and into the “New Paradigm”

In recent years, the National Highway Traffic Safety Administration (NHTSA) has received increased public and Congressional scrutiny stemming from high-profile safety defects, such as the Toyota unintended-acceleration issues...more

6/11/2015 - Auto Manufacturers Automobile Recall Automotive Industry Consent Order Department of Transportation Enforcement GROW AMERICA Act Investigations Manufacturing Defects Motor Vehicles NHTSA Product Defects

NHTSA's Enforcement Priorities Made Clear in U.S. DOT's Transportation Bill (Grow America Act)

Last year, the U.S. Department of Transportation unveiled its long-term transportation bill, entitled the Grow America Act, which contained the Department’s wish list for funding and new authorities. On March 31, 2015, the...more

4/28/2015 - DOT Funding GROW AMERICA Act Infrastructure NHTSA Proposed Legislation Surface Transportation

What's Next for NHTSA and Automotive Safety?

This past year, we witnessed the GM Ignition Switch investigation, which involved massive recalls, multiple Congressional hearings, and civil penalties; the ongoing Takata airbag inflator investigation and recalls (and more...more

1/22/2015 - Auto Manufacturers Automobile Recall Automotive Industry Distracted Driving Driverless Cars Enforcement Actions General Motors NHTSA Takata V2V

Top Legal Issues Facing Automotive Suppliers in 2015

Foley’s Automotive Industry Team has prepared this overview of the major trends we see affecting automotive suppliers this year. While not all legal risk can be anticipated, companies that are aware of litigation,...more

1/12/2015 - ADA Antitrust Provisions Auto Manufacturers Auto Parts Automobile Recall Automotive Industry DOJ Employer Liability Issues Export Controls FCPA Manufacturers NHTSA NLRB Suppliers V2V

NHTSA's September Scrutiny

September was a difficult month for NHTSA. During one week alone, a New York Times article blasted NHTSA for failing to investigate a number of defects that later resulted in injuries and fatalities and, ultimately, recalls;...more

10/3/2014 - Automobile Recall Automotive Industry Car Accident General Motors NHTSA

A Busy Year for NHTSA Enforcement and Rulemaking

This promises to be one of NHTSA’s busiest years for enforcement and rulemaking activity. NHTSA is expected to continue its aggressive enforcement, sparked by GM’s massive ignition switch recall and the flood of follow-on...more

9/18/2014 - Auto Manufacturers Automobile Recall Automotive Industry Enforcement General Motors NHTSA Rulemaking Process Strategic Enforcement Plan

NHTSA and GM Agree to Resolve Timeliness Claims Related to Ignition Switch Recall

Last week, NHTSA and GM announced an agreement to resolve recall timeliness claims related to GM’s massive Ignition Switch recall. In addition to the widely-reported $35 million civil penalty GM has agreed to pay (the maximum...more

5/21/2014 - Automobile Recall Automotive Industry General Motors NHTSA

A Peek at NHTSA Provisions in the DOT's Transportation Bill

Last week, the U.S. Department of Transportation (DOT) unveiled its long-term transportation bill, entitled the Grow America Act, which it is sending to Congress for consideration. Among other things, the bill contains...more

5/6/2014 - Automotive Industry DOT GROW AMERICA Act NHTSA Proposed Amendments Trucking Industry

Auto Suppliers Prepare for Barrage of Recalls

With the recent high-profile recalls involving Toyota and GM, auto suppliers are anticipating a spike in recalls and asking themselves how to prepare for this inevitability. As a start, auto suppliers need to...more

4/23/2014 - Automobile Recall Automotive Industry General Motors NHTSA Toyota

Top Legal Issues Facing Suppliers in 2014

We know that you have been considering what business and commercial issues you will face in 2014 (and perhaps beyond) as an Automotive Supplier. But, have you been considering what legal issues you are likely to face? Do you...more

2/18/2014 - Automotive Industry Compliance Data Protection FCPA NHTSA Suppliers Supply Chain Trucking Industry

New Requirements for NHTSA Recalls and Early Warning Reporting Become Effective October 21

In August, NHTSA adopted numerous amendments to its recall and early warning reporting (EWR) regulations. (See 78 Federal Register 51382 (Aug. 20, 2013)). Several of these amendments – which impact all vehicle and equipment...more

10/18/2013 - Defect Early Warning Regime NHTSA Product Recalls Safety Precautions

Auto Parts Distributor Avoids Liability In Robinson-Patman Suit

On July 19, 2013, the Ninth Circuit affirmed an award of summary judgment to an aftermarket auto parts distributor that had received better prices than a competitor. Gorlick Distribution Centers, LLC v. Car Sound Exhaust...more

8/13/2013 - Automotive Industry Commodities Competition Distributors Purchase Price Robinson-Patman Act Summary Judgment

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