Hurst v. Nissan North America, Inc.
529 S.W.3d 322 (2017)
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Rule of Law:
A manufacturer's advertising statements describing a product as "premium" or "luxury" are not proven false under the Missouri Merchandising Practices Act merely by evidence that a single, high-end component of the product is defective. To prove such statements false, a plaintiff must show the product was constructed with low-end or standard components inconsistent with the representation of quality.
Facts:
- Beginning in 2003, Nissan North America, Inc. manufactured and sold Infiniti FX vehicles.
- Nissan marketed these vehicles in promotional materials with statements describing them as "premium," "luxury," and a "leader in style."
- Starting in 2005, Nissan began receiving complaints that the dashboards in these vehicles were defective, tending to deform or "bubble" when exposed to heat and humidity.
- Nissan provided a warranty covering defective parts, including the dashboards, and later extended the warranty's length specifically for this issue.
- To address the defect, Nissan changed its dashboard suppliers twice.
- Nissan ultimately replaced more than 45,000 defective dashboards at no cost to vehicle owners.
- Robert Hurst, along with other class members, purchased an Infiniti FX vehicle in Missouri with the original manufacturer's dashboard.
Procedural Posture:
- Robert Hurst, on behalf of a class of plaintiffs, sued Nissan North America, Inc. in a Missouri trial court for violations of the Missouri Merchandising Practices Act.
- After preliminary litigation, the trial court certified a class consisting of Missouri purchasers of the specified vehicles.
- The case proceeded to a jury trial, where the jury returned a verdict in favor of the plaintiffs.
- The trial court entered a final judgment ordering Nissan to pay $2,000 in damages to each class member and $1.9 million in attorney fees.
- Nissan, as appellant, appealed the trial court's judgment.
- The Missouri Supreme Court granted transfer to hear the appeal.
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Issue:
Does a car manufacturer make a false misrepresentation under the Missouri Merchandising Practices Act by advertising its vehicles as "luxury" and "premium" when the vehicles contain a high-end dashboard that is susceptible to a defect?
Opinions:
Majority - Wilson, J.
No. A car manufacturer does not make a false misrepresentation under the Missouri Merchandising Practices Act by advertising its vehicles as 'luxury' when they contain a defective high-end component. The court, assuming for the sake of argument that terms like 'luxury' are factual statements rather than mere puffery, held that the plaintiffs failed to present evidence that these statements were false. The evidence showed the dashboards were defective, not that they were low-end, economy, or standard parts inconsistent with a luxury vehicle. The court reasoned that a reasonable consumer would not interpret 'luxury' or 'premium' to mean that every single component is entirely free of any potential defect, an inference made unreasonable by the very existence of a manufacturer's warranty designed to cover such defects.
Dissenting - Draper, J.
This opinion was noted but its text was not included in the provided case materials.
Analysis:
This decision significantly clarifies the evidentiary standard for misrepresentation claims under the Missouri Merchandising Practices Act (MMPA). By distinguishing between a product being of a lower quality than advertised and a high-quality product containing a manufacturing defect, the court narrows the scope of actionable claims. It signals that consumer protection statutes may not cover claims where the harm is an isolated defect, particularly when a warranty provides a remedy. This precedent forces future plaintiffs to prove that a product's overall character and components are fundamentally inconsistent with its marketing, rather than just pointing to a single flawed part to claim the advertising was false.
