GEDDIS WRIGHT v. AMERICAN HONDA MOTOR COMPANY INC (2025)

MEMORANDUM OPINION AND ORDER DISMISSING THIS MATTER WITHOUT PREJUDICE FOR LACK OF SUBJECT MATTER JURISDICTION

I. INTRODUCTION

Plaintiffs Shavonne Geddis-Wright (Geddis-Wright), individually and on behalf of all others similarly situated, filed this putative class action against Defendant American Honda Motor Company, Inc. (Honda). She asserts federal and state law claims arising from brake system defects in vehicles manufactured, distributed, and warranted by Honda. The Court has jurisdiction as per 28 U.S.C. §§ 1331 and 1367.

Pending before the Court is Honda's motion to dismiss for failure to state a claim. Having carefully considered the motion, the response, the reply, the record, and the applicable law, the Court concludes Geddis-Wright's claims are unripe for judicial review. It is therefore the judgment of the Court this matter will be dismissed without prejudice for lack of subject matter jurisdiction, necessarily deeming as moot Honda's motion to dismiss.

II. FACTUAL AND PROCEDURAL HISTORY

As is relevant here, Honda manufactured the 2020 and 2021 Honda Civic; the 2020, 2021, 2022, and 2023 Honda Ridgeline; the 2021, 2022, and 2023 Honda Passport; the 2021 and 2022 Honda Pilot; and the 2020 Acura MDX (collectively, the Subject Vehicles).

Several years ago, Geddis-Wright purchased a 2020 Honda Civic from Stokes Honda in North Charleston, South Carolina. Geddis-Wright claims she “decided on the 2020 Honda Civic because she believed it was a high-quality vehicle after a salesman convinced her [it] was highly reliable and came with great technological features at a more affordable price than the Honda Accord.” Amended Complaint ¶ 31.

In the summer of 2023, Honda initiated a National Highway Traffic Safety Administration (NHTSA) recall for the Subject Vehicles due to a “problem stem[ming] from improper assembly of the tie rod fastener that connects brake master cylinder and the brake booster.” Id. ¶ 21. Geddis-Wright claims, “[d]uring the application of the brake pedal, a bending load may occur upon the brake booster assembly tie rod studs. As a result, the tie rod studs may break, leading to the brake master cylinder separating from the brake booster assembly and a failure to comply with Federal Motor Vehicle Safety Standards (FMVSS) 135 – Light vehicle brake systems.” Id.

Geddis-Wright acknowledges Honda's recall program “includes a free fix and repair clause in which [Honda agreed to] repair and fix the faulty parts[.]” Id. ¶ 32. But, Geddis-Wright alleges a repair “will cost ․ hours of her time” and “does not offer any foreseeable guarantee that the [b]rake [d]efect will go away permanently.” Id. ¶¶ 32–33. Geddis-Wright further maintains, “[e]ven if one was to presume that the [r]ecall was effective and offered a true fix, which is by no means a fair presumption, [she] is still burdened with a vehicle that has been devalued by [Honda]’s actions ․” Id. ¶ 34.

Thus, as the Court stated above, Geddis-Wright filed this putative class action. She seeks damages for breach of the implied warranty of merchantability, fraud by omission or fraudulent concealment, unjust enrichment, design defect, manufacturing defect, and violations of the Magnuson-Moss Warranty Act (MMWA), 15 U.S.C. §§ 2301–2312.

As the Court indicated above, Honda filed a motion to dismiss for failure to state a claim. Geddis-Wright responded, and Honda replied. But, having been fully briefed on ripeness, the Court determines it is without subject matter jurisdiction to consider Geddis-Wright's claims.

III. STANDARD OF REVIEW

“The doctrine of ripeness arises from the case or controversy requirement of Article III.” Whitaker v. Monroe Staffing Servs., LLC, 42 F.4th 200, 206 (4th Cir. 2022). It “prevents judicial consideration of issues until a controversy is presented in ‘clean-cut and concrete form.’ ” Miller v. Brown, 462 F.3d 312, 318–19 (4th Cir. 2006) (quoting Rescue Army v. Mun. Ct. of L.A., 331 U.S. 549, 584 (1947)). “The burden of proving ripeness falls on the party bringing suit.” Id. at 319 (citing Renne v. Geary, 501 U.S. 312, 316 (1991)).

“In evaluating the ripeness of claims for judicial review, courts must balance the fitness of the issues for judicial decision and the hardship to the parties of withholding court consideration.” Franks v. Ross, 313 F.3d 184, 194 (4th Cir. 2002) (internal quotation marks omitted) (quoting Ohio Forestry Ass'n, Inc. v. Sierra Club, 523 U.S. 726, 733 (1998)).

The fitness prong requires “the issues [in the case to be] purely legal and ․ the action in controversy [to be] final and not dependent on future uncertainties.” Miller, 462 F.3d at 319 (citing Charter Fed. Sav. Bank v. Off. of Thrift Supervision, 976 F.2d 203, 208 (4th Cir. 1992)). “A claim should be dismissed as unripe if the plaintiff has not yet suffered injury and any future impact ‘remains wholly speculative.’ ” Doe v. Va. Dep't of State Police, 713 F.3d 745, 758 (4th Cir. 2013) (quoting Gasner v. Bd. of Supervisors,103 F.3d 351, 361 (4th Cir. 1996)).

“The hardship prong is measured by the immediacy of the threat and the burden imposed” upon the plaintiff. Charter Fed. Sav. Bank, 976 F.2d at 208–09. “When considering hardship, [the Court] may consider the cost to the parties of delaying judicial review.” Miller, 462 F.3d at 319.

IV. DISCUSSION AND ANALYSIS

Honda argues Geddis-Wright's claims are unripe because she has neglected to allege a concrete and particularized injury. Honda notes Geddis-Wright has neither established her vehicle is defective nor availed herself of the recall program, which would provide complete relief. Rather, Honda posits, Geddis-Wright “is speculating that the recall may not adequately address the defects she alleges and as a result, [she] may suffer continued injury in the future, if and when she takes advantage of the free repairs [Honda] is offering.” Supplemental Briefing at 13 (emphasis omitted).

Geddis-Wright, on the other hand, avers she has alleged an actual injury in the form of “purchasing [a] defective vehicle[ ], enduring the safety risks of operating the[ ] vehicle[ ], and incurring economic damages such as overpayment at the time of purchase and diminished resale value.” Geddis-Wright's Response at 3. Geddis-Wright contends Honda's recall program is incomplete, fails to fully compensate her losses, and neglects to sufficiently address ongoing safety concerns. She also insists “[d]ismissing th[is] case would leave her without an adequate remedy, forcing her to drive an unsafe car and accept a financial loss.” Geddis-Wright's Response at 6.

In the amended complaint, Geddis-Wright alleges “[she] suffered an injury-in-fact due to an economic loss [because] all [r]ecalled vehicles were defective at the moment of purchase[.]” Amended Complaint ¶ 27. She claims “[t]he economic harm can be seen as overpayment, loss of value or loss of usefulness emanating from the loss of the benefit of the bargain[,]” and “loss of resale value.” Id.

Absent from the complaint, however, is any contention Geddis-Wright has experienced an issue with her braking system. In fact, it remains unclear whether Geddis-Wright's vehicle is defective, as she evidently refuses to commute to the dealership for an inspection. See id. ¶ 31 (“The result of [Honda]’s recall, which includes a free fix and repair clause in which [Honda] will repair and replace the faulty parts, will cost [Geddis-Wright] hours of her time.”); id. ¶ 40 (“In addition to the sheer amount of time spent in repair, [Geddis-Wright] ․ must spend time and money to transport herself and her defective [vehicle] to a Honda certified mechanic.”). And, the NHTSA recall report—which Geddis-Wright cites in the amended complaint—estimates less than one percent of the Subject Vehicles suffers from the defect.

It is evident from the complaint and briefing Geddis-Wright has neglected to avail herself of the recall program. And, as the Court noted above, Geddis-Wright acknowledges “includes a free fix and repair clause in which [Honda] will repair and replace the fault parts[.]” Id. ¶ 32. Instead, as the Court stated above, Geddis-Wright protests the program, alleging a repair “will cost ․ hours of her time” and fails to “offer any foreseeable guarantee that the [b]rake [d]effect will go away permanently.” Id. ¶ 33.

Following the reasoning established by other courts, the Court determines these allegations are unable to overcome the speculative nature of Geddis-Wright's injuries. See, e.g., Wilson v. Gen. Motors, LLC, No. 5:20-cv-6061, 2021 WL 12311013, at *4 (W.D. Mo. June 15, 2021) (determining the plaintiffs failed to satisfy the fitness prong where they neglected to take advantage of the defendant's offer of a free replacement to repair their defective engine block heaters); Elkins v. Am. Honda Motor Co., No. 8:19-cv-818, 2020 WL 4882412, at *5 (C.D. Cal. July 20, 2020) (holding issues were unfit for judicial decision where eleven plaintiffs had yet to avail themselves of the defendant's warranty extension program for defective air condition condensers and nine of their repaired air condition systems were functioning).

Simply put, the Court is persuaded “the action in controversy [here] is ․ dependent on future uncertainties.” Miller, 462 F.3d at 319 (citing Charter Fed. Sav. Bank, 976 F.2d at 208); see Doe, 713 F.3d at 758 (“A claim should be dismissed as unripe if the plaintiff has not yet suffered injury and any future impact ‘remains wholly speculative’․ Like the redressability requirement for standing, [the] ripeness doctrine prevents us from considering a controversy until it is presented in ‘clean-cut and concrete form.’ ” (first quoting Gasner, 103 F.3d at 361; and then quoting Rescue Army v. Mun. Ct. of L.A., 331 U.S. 549, 584 (1947))). The Court thus determines Geddis-Wright has failed to satisfy the fitness prong of the ripeness inquiry.

Turning to the second prong, the Court is likewise unpersuaded Geddis-Wright would suffer undue hardship by the Court withholding judicial review. Indeed, as the Court explained above, it appears Geddis-Wright has yet to experience any issues with her braking system. And, any future hardships Geddis-Wright may face will be purely financial and potentially cured by the fix and repair clause of the recall program. See, e.g., Wilson, 2021 WL 12311013, at *4 (finding the plaintiffs failed to meet the hardship prong where the free replacement offered by the defendant may address the plaintiffs’ injuries); Elkins, 2020 WL 4882412, at *6 (concluding the eleven plaintiffs were unable to demonstrate hardship where all but two of their repaired air condition systems were functioning and any future loss would perhaps be covered by the defendant's extended warranty program).

Accordingly, the Court holds Geddis-Wright's claims are unripe for judicial review. The Court therefore concludes this matter should be dismissed for lack of subject matter jurisdiction. See Doe, 713 F.3d at 758 (“A claim should be dismissed as unripe if the plaintiff has not yet suffered injury and any future impact ‘remains wholly speculative.’ ” (quoting Gasner,103 F.3d at 361)). And, because ripeness is dispositive, it is unnecessary for the Court to address the remaining arguments advanced by the parties. See Karsten v. Kaiser Found. Health Plan of Mid-Atlantic States, Inc., 36 F.3d 8, 11 (4th Cir. 1994) (“If the first reason given is independently sufficient, then all those that follow are surplusage; thus, the strength of the first makes all the rest dicta.”).

V. CONCLUSION

Wherefore, based on the foregoing discussion and analysis, it is the judgment of the Court this matter is DISMISSED WITHOUT PREJUDICE for lack of subject matter jurisdiction. And, as a result of the Court's ruling, Honda's motion to dismiss for failure to state a claim is necessarily deemed as moot.

IT IS SO ORDERED.

MARY GEIGER LEWIS, UNITED STATES DISTRICT JUDGE