Universal Motors, Inc. v. Waldock

In Universal Motors, Inc. v. Waldock, 719 P.2d 254 (Alaska 1986), the court analyzed the shifting burden of proof in a Magnuson-Moss action. Once the consumer offers credible evidence that the defect is related to materials or workmanship, thus establishing a prima facie case of breach of warranty, the burden shifts to the warrantor to prove consumer abuse. Id. at 259. The Alaska court noted the specific language of 15 U.S.C. 2304(c) "places the burden of proving owner abuse squarely on the warrantor." Waldock, 719 P.2d at 256.