In Carl Cieslikowski V. FCA US, LLC, No. 19-55679 (9th Cir. 2020), the jury awarded $500,000 in punitive damages arising out of the sale of an allegedly defective Jeep, and the trial court vacated that award. On appeal, the plaintiffs argued that the district court erred in determining that the evidence was inadequate to support the jury?s verdict on their fraudulent concealment claim. And the Ninth Circuit agreed, holding that a California magistrate judge improperly overturned the jury’s $500,000 punitive damages award, and reversed in part.
The Court reasoned that substantial evidence supported the jury?s verdict when viewing the record in the light most favorable to the plaintiffs, and determined that a reasonable jury could conclude that Chrysler knew of the defective power module in the Jeep when it sold that vehicle. There was evidence suggesting that the modules were materially similar across Chrysler?s vehicle models, that they shared common and obvious defects that caused the vehicle engines to stall or to fail to start, that Chrysler knew of the problem, and that Chrysler did not know whether the problem had been solved. In light of the evidence, the jury could reasonably infer that Chrysler committed fraud when it sold the Jeep to the plaintiffs and assured them that the electrical problems affecting their previous Jeep had been resolved.
The case was reversed in part and remanded to the district court to decide in the first instance whether substantial evidence supported the jury?s punitive damages verdict.