Ysbrand v. DaimlerChrysler Corp

In Ysbrand v. DaimlerChrysler Corp., 2003 OK 17, 81 P.3d 618, DaimlerChysler argued that there was no predominance because of the need for individual proof of each class member's reliance on the express warranty. The Oklahoma Supreme Court disagreed, stating: "Whether individual findings of reliance are required goes to the merits of the claims. It is a question of Michigan law. A need for individual findings would not, however, defeat class certification. "Factual variations in the individual claims will not normally preclude class certification if the claim arises from the same event or course of conduct as the class claims, and gives rise to the same legal or remedial theory." Lobo Exploration Co. v. Amoco Production, 1999 OK CIV APP 112, 991 P.2d 1048, 1055 (quoting Alpern v. Utili Corp United, Inc., 84 F.3d 1525, 1540 (8th Cir. 1996). . . . The trial court remains free to maintain the class with respect to particular issues or create subclasses should the need arise. See Okla. Stat. tit. 12, 2023(C)(4)(2001)." Finding that Michigan law applied because that was where the company had its principal place of business and made its business decisions about the design, manufacture, and distribution of the minivans, the Court stated: "The needs of the interstate system and the basic policies of predictability and uniformity of result require that the issue of product defect be determined in one forum with one result rather than in 51 jurisdictions with the very real possibility of conflicting decisions. While the interest of each home state in applying its local law is significant, Michigan's interest in the conduct of its manufacturer, and thus its connection to the warranty issues, is greater. Michigan law applies. It should be noted that this conclusion is consistent with the constitutional imperative that "for a state's substantive law to be selected in a constitutionally permissible manner, that state must have a significant aggregation of contacts, creating state interests, such that choice of its law is neither arbitrary nor fundamentally unfair." Phillips Petroleum Co. v. Shutts, 472 U.S. 797 (1985) (quoting Allstate Ins. Co. v. Hague, 449 U.S. 302 (1981))." Id.