Daugherty v. American Honda Motor Co

In Daugherty v. American Honda Motor Co. (2006) 144 Cal.App.4th 824, the plaintiffs argued that Honda's warranty did not require discovery of the defect during the warranty period if Honda was aware of the defect at the time of sale. The court rejected the plaintiffs' argument, noting that numerous courts have found that a latent defect that is discovered after the express warranty has expired cannot form the basis for a breach of express warranty claim. (Id. at pp. 831-832.) The court in Daugherty reasoned: "in giving its promise to repair or replace any part that was defective in material or workmanship and stating the car was covered for three years or 36,000 miles, Honda 'did not agree, and plaintiffs did not understand it to agree, to repair latent defects that lead to a malfunction after the term of the warranty.'" (Daugherty, supra, 144 Cal.App.4th at p. 832.) The court stated further: "'virtually all product failures discovered ... after expiration of the warranty can be attributed to a "latent defect" that existed at the time of sale or during the term of the warranty. All parts will wear out sooner or later and thus have a limited effective life. Manufacturers always have knowledge regarding the effective life of particular parts and the likelihood of their failing within a particular period of time, and can always be said to "know" that many parts will fail after the warranty period has expired. A rule that would make failure of a part actionable based on such "knowledge" would render meaningless time/mileage limitations in warranty coverage.'" (Daugherty, supra, 144 Cal.App.4th at p. 830.)