JPML Denies Centralization of Defective Air Conditioner Class Actions

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UPDATE: Individual class action lawsuits over allegedly defective Goodman air conditioners continue, despite the JPML’s denial of centralization. Goodman filed a motion Feb. 26, 2014, to remove one of the class action lawsuits to federal court, saying it faces over $803 million in damages.

The U.S. Judicial Panel on Multidistrict Litigation has squashed the centralization of class action lawsuits regarding allegedly defective Goodman air conditioners, Amana air conditions and related products, saying the proposed Classes are too different and the number of complaints too small to warrant consolidation.

Two putative defective design class action lawsuits have been filed in Florida and one in California, and all three allege that Goodman failed to properly design evaporator coils that function to remove heat from the air that will be pumped into a room. According to plaintiffs, the thickness of the copper used was not sufficient and the coils broke under the stress of the temperature differentials.

According to the original class action lawsuit filed (PB Property Management Inc. v. Goodman Manufacturing Company, L.P.), heat pumps and air conditioners reportedly malfunctioned at a high rate, and “according to a Goodman dealer, approximately 80 percent of the Goodman Products his company had sold and/or installed had experienced refrigerant leakage problems” over the course of several years, yet the company did not disclose these concerns to purchasers. The consumers’ class action lawsuits make similar allegations regarding a problematic failure rate.

JPML Chairman John G. Heyburn II noted, however, that while two of the class action lawsuits had Classes that would be predominantly comprised of homeowners and consumers, the legal action initiated by PB Property Management would focus on commercial entities. More importantly, the panel saw little need for consolidation of the cases involving Amana air conditioners because “these actions uniformly involve relatively simple warranty claims and straightforward discovery,” and “there is no threat of conflicting class certification rulings.”

It also does not mean that there will need to be repetition of pre-trial activities including discovery. Judge Heyburn noted that class action lawyers from California had already contacted those in Florida to begin coordinating motions and depositions for the defective design class action lawsuits. As Goodman Manufacturing had already supported multidistrict litigation, the panel saw no likelihood of further problems.

The proposed multidistrict litigation would have been In re: Goodman Manufacturing Co. LP HVAC Products Liability Litigation, MDL No. 2499.