Law School Case Brief
Hahn v. Ford Motor Co. - 434 N.E.2d 943 (Ind. Ct. App. 1982)
Section 2301 of the Magnuson-Moss Warranty Act, 14 U.S.C.S. § 2301 et seq., defines consumer goods to include tangible personal property distributed in commerce and normally used for personal, family or household purposes. The Act provides the types and methods of disclaimer and modification one may employ with regard to implied warranties. It applies exclusively to disclaimers and modifications contained in written warranties.
Appellants Michael and Judith Hahn initiated an action against Ford Motor Company (Ford) and *** Lorey Ford, Inc. (Lorey) for breach of warranties on a 1977 Ford LTD II. Lorey counterclaimed for the balance due on the purchase price of the vehicle. At trial the jury rendered a verdict in favor of Ford and Lorey and against the Hahns on the breach of warranties action; the jury also held in favor of Lorey on its counterclaim, awarding damages of $2,900. The Hahns argued that the trial court erred when it admitted the automobile's warranty book into evidence, when it granted judgment in favor of the manufacturer on the issue of punitive damages, and when it refused to give the Hahns' requested jury instruction.
Did the trial court err in admitting the warranty book into evidence, even though Hahns did not consent to the booklet?
The court found that the trial court correctly admitted the warranty book into evidence, even though the Hahns did not consent to the booklet, because Ford made a prima facie showing that the purchasers' had knowledge of the limitation of the duration of the implied warranties provided in the booklet when the agreement was signed. The court found that the limitation of remedies was not so one-sided as to be unconscionable, and that a limitation of remedies was not prohibited by the Magnuson-Moss Warranty Act, 14 U.S.C.S. § 2301 et seq. The court held that judgment for Ford on the punitive damages issue was proper because the jury found that there was no breach of warranty, and that the denial of the Hahns’ jury instruction was proper because the subject was adequately covered by the trial court's jury instructions.
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