Motion for Summary Adjudication
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SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA 24CV089471: YOB vs AMERICAN HONDA MOTOR CO., INC., et al. 06/04/2026 Hearing on Motion for Summary Adjudication filed by AMERICAN HONDA MOTOR CO., INC. (Defendant) CRS# 921426355305 in Department 24 Tentative Ruling - 06/02/2026 Rebekah Evenson The Motion for Summary Adjudication filed by AMERICAN HONDA MOTOR CO., INC. on 03/02/2026 is Granted. Defendants Motion for Summary Adjudication as to Plaintiffs Fifth Cause of Action for Fraudulent Inducement Concealment is GRANTED.
The evidence submitted in connection with this motion establishes that Plaintiffs Fifth Cause of Action for Fraudulent Inducement Concealment is barred by the economic loss rule. Plaintiff alleges he entered a warranty contract with Defendant. (See Complaint, paragraph 6.) Under the economic loss rule, tort recovery for breach of a contractual duty is generally barred unless two conditions are satisfied. The plaintiff must first demonstrate the defendants injurycausing conduct violated a duty that is independent of the duties and rights assumed by the parties when they entered the contract.
Second, the defendants conduct must have caused injury to persons or property that was not reasonably contemplated by the parties when the contract was formed. (See Rattagan v. Uber Technologies Inc. (2024) 17 Cal.5th 1, 20-21.) The economic loss rule does not apply if the defendants breach caused physical damage or personal injury beyond the economic losses caused by the contractual breach. (Id. at 26, 44.) The Court will assume, for purposes of this motion, that Defendants alleged failure to disclose purported transmission defects affecting Plaintiffs vehicle violated a duty independent of the contractual duties under the warranty agreement.
However, Plaintiff has presented no evidence of any injury to persons or property that was not reasonably contemplated when by the parties when they entered into the warranty agreement. The very existence of a warranty presupposes that some vehicle defects may occur. (See Santana v. FCA US LLC (2020) 56 Cal.App.5th 334, 345; see also Rattagan, supra, 17 Cal.5th at 37.) Where, as here, the defendants alleged breach of duty is based on its failure to perform as the contract requires (i.e., to repair any vehicle defects pursuant to the warranty), the cause of action will generally sound only in contract because a breach deprives the injured party of the benefit it bargained for. (Id. at 27.)
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Plaintiff has presented no evidence that he suffered any personal injury or physical damage to property, or any damage beyond the economic loss caused by Defendants alleged breach of warranty. Specifically, the only evidence of damage identified by Plaintiff is the difference between the price paid for his vehicle and the unspecified actual market value of the vehicle if its purported defects had been disclosed. (See Defendants Separate Statement Facts Nos. 13-14, Plaintiffs response, and the evidence in support.)
Because Plaintiff has presented no evidence that he suffered any injury to persons or property, or any other type of loss that was not reasonably contemplated by the parties when they entered the
SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA 24CV089471: YOB vs AMERICAN HONDA MOTOR CO., INC., et al. 06/04/2026 Hearing on Motion for Summary Adjudication filed by AMERICAN HONDA MOTOR CO., INC. (Defendant) CRS# 921426355305 in Department 24 warranty agreement, Plaintiffs Fifth Cause of Action for Fraudulent Inducement Concealment is barred by the economic loss rule. Plaintiffs Request for Judicial Notice is GRANTED. However, it is not clear why recall reports and service notices for other models of vehicles are relevant to Plaintiffs claims.
The Court rules as follows on Plaintiffs Objections to Evidence: Objections Nos. 1-2 are SUSTAINED, as lacking personal knowledge or proper authentication. Defense counsel Rosina Saeed does not demonstrate any personal knowledge as to Plaintiffs Retail Installment Contract or Hondas Warranty Booklet and lacks a foundation to authenticate those documents. However, Plaintiff himself relied upon Hondas Warranty Booklet in opposing this motion (see Plaintiffs response to Separate Statement Fact No. 4), so the Court considered the Warranty Booklet in ruling on this motion.
Objections Nos. 3-4 are OVERRULED on the grounds asserted. Plaintiffs Fifth Cause of Action for Fraudulent Inducement Concealment is DISMISSED.