Mazza, et al. v. American Honda Motor Co., No. 09-55376 ((9th Cir. 2012), presents a related analysis to that of the Seventh Ciruit in our recent posting on class or collective actions. Here, however, the Court of Appeals vacated and reversed the grant of class certification.
As defined in the district court, the class consisted of a nationwide class of all consumers who purchased or leased an Acura equipped with a Collision Mitigation Braking System. The gravamen of the claim was that defendant misrepresented the characteristics of the braking system. The district court determined that all such claims could be adjudicated under California law. The district court also presumed reliance, something which the Ninth Circuit took issue with but is not discussed further below.
In reversing, the Ninth Circuit held that the district court “erred because it erroneously concluded that California law could be applied to the entire nationwide class”. The Court of Appeals also reversed because the district court “concluded that all consumers who purchased or lease the Acura RL can be presumed to have relied on defendant’s advertisements."
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