Judge Won’t Dismiss AutoZone Class Action Lawsuit

A plaintiff request for voluntary dismissal was recently denied by a federal judge, finding that the defendants in the AutoZone class action lawsuit have invested too much time and effort into litigation for dismissal without prejudice.

U.S. District Judge Staci M. Yandle recently denied a motion for voluntary dismissal without prejudice by plaintiffs Steve Williamson and Rhonda Christine LeMaster. In her motion, Judge Yandle noted that the request for voluntary dismissal came only after the court denied class certification leading her to suspect that plaintiffs want to avoid any defendant motion for summary judgment.

“This case is over three years old, and defendants have expended an enormous amount of time and resources defending against plaintiff’s claims and request for class certification,” Judge Yandle wrote in her ruling. “The parties have engaged in extensive discovery, including voluminous written discovery, expert witness disclosures and depositions, depositions of defendants’ corporate representative and depositions of both plaintiffs.”

The AutoZone class action was first filed in 2015, alleging that AutoZone and S.A. Gear manufactured and sold defective timing chain tensioners. These parts work to make sure that the timing chain in the engine works efficiently, ensuring that the engine’s valves open and close at the same time. However, according to Williamson and LeMaster, the parts sold by AutoZone do not work with Chrysler engines despite alleged representations to the contrary.

The litigation process for the AutoZone class action has not been easy for the plaintiffs or the defendants. In December 2016, AutoZone motioned for dismissal, arguing that the product descriptions brought by plaintiffs were “puffery” and did not constitute a written warranty. In January 2017, Judge Yandle partially denied and partially granted AutoZone’s motion for dismissal, leaving plaintiff claims for breach of written warranty and common law fraud but dismissing fraudulent concealment, breach of implied warranty of merchantability, and RICO claims.

This June, to the detriment of the plaintiffs, Judge Yandle denied a class certification for a proposed Class of consumers who purchased the part in question, finding that the plaintiffs failed to reference a specific injury or time frame. She noted that this class could include consumers who were not injured by the alleged defect. Following this denial, the plaintiffs motioned for voluntary dismissal of the class action lawsuit.

In early September, the defendants in the AutoZone class action lawsuit protested the plaintiff motion for voluntary dismissal. The companies claimed that the motion was an attempt at forum shopping because of the denial of class certification. AutoZone and S.A. Gear then requested that Judge Yandle order summary judgement since discovery was finished.

“Unfavorable rulings are not an acceptable basis to grant a voluntary dismissal or ‘to facilitate the search for a perceivably more favorable state judicial climate,'” Judge Yandle wrote, citing a separate case.

Plaintiffs are represented by Gregory J. Pals and John J. Driscoll of The Driscoll Firm PC.

The AutoZone Class Action Lawsuit is Williamson v. S.A. Gear Co. Inc. et al., Case No. 3:15­cv­00365, in the U.S. District Court for the Southern District of Illinois.