Young v. Ford Motor Co., Inc.
1992 WL 41918, 595 So. 2d 1123 (1992)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Under Louisiana law, a buyer may recover damages for nonpecuniary loss (mental anguish) in a redhibition action for a defective product that does not cause physical injury, but only if the buyer proves that gratification of a significant nonpecuniary interest was a primary purpose of the contract, pursuant to La. Civ. Code art. 1998.
Facts:
- On January 15, 1988, Iray Young, a service station owner, purchased a new 1988 Ford Supercab pickup truck from Bordelon Motors, Inc.
- Young intended to use the truck for his service station business and for personal recreation and pleasure.
- Within three days of purchase, Young returned the truck to the dealer complaining of an engine knock, which was the first of numerous major and persistent defects.
- Over the next several months, the truck required constant, extensive repairs, including the replacement of the ignition switch, air pollution pumps, and the entire short block assembly, rendering it frequently unusable.
- The ongoing problems with the truck caused Young to suffer significant emotional distress, including sleeplessness, frustration, and depression, for which his doctor prescribed medication.
Procedural Posture:
- Iray Young filed a redhibition action against Ford Motor Company, Inc. and Bordelon Motors, Inc. in a Louisiana district court (trial court).
- A jury rendered a verdict for Young, awarding him the purchase price, rental charges, attorney's fees, and $3,750 for mental anguish.
- Ford Motor Company and Bordelon Motors (appellants) appealed to the Louisiana Third Circuit Court of Appeal, challenging only the award for mental anguish damages.
- The Court of Appeal reversed the trial court's judgment solely on the issue of mental anguish damages, vacating that portion of the award.
- Iray Young (applicant) sought and was granted a writ of review by the Supreme Court of Louisiana to address the availability of mental anguish damages.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does Louisiana law permit the recovery of mental anguish damages in a redhibition action for a defective product that has not caused physical injury?
Opinions:
Majority - Calogero, C.J.
Yes, Louisiana law permits the recovery of mental anguish damages in such cases, but only when the specific requirements of Louisiana Civil Code article 1998 are met. The court determined that redhibition claims for damages under Article 2545 are governed by the general contract damages principles in Article 1998. Article 1998 allows for nonpecuniary damages when the contract's nature is intended to gratify a significant nonpecuniary interest and the seller should have known that nonperformance would cause such loss. Reviewing legislative history and prior case law, the court held that while a contract can have both pecuniary and nonpecuniary objectives, the nonpecuniary interest must be 'significant,' not merely incidental. Here, Young failed to prove that a significant nonpecuniary interest was a primary reason for purchasing the truck; its purpose was predominantly pecuniary (business use and transportation). Therefore, although such damages are legally recoverable in principle, Young did not meet the factual burden of proof required by Article 1998.
Concurring - Marcus, J.
Yes, but the standard should be higher than the majority's 'significant interest' test. To recover mental anguish damages, the principal object or cause of the contract must be the gratification of a nonpecuniary interest. Using the word 'nature' in Article 1998 implies that the nonpecuniary interest must define the inherent character of the contract, not just be a significant factor. This stricter standard is necessary to prevent mental anguish claims in ordinary commercial transactions where the primary purpose is pecuniary.
Concurring - Dennis, J.
Yes, but the claim fails on foreseeability. Recovery for nonpecuniary loss requires showing that the obligor knew or should have known its failure to perform would cause the kind of loss claimed. While Ford should have anticipated that a defective truck would cause annoyance and frustration, it could not have reasonably been expected to foresee the extreme psychogenic symptoms—depression, insomnia, and impotency—that Young experienced. The damages were not of the kind a seller would reasonably anticipate from this type of breach.
Analysis:
This case clarifies the standard for recovering nonpecuniary damages in Louisiana contract and redhibition law where no physical injury occurs. It affirms that such damages are available but establishes the 'significant nonpecuniary interest' test, creating a substantial evidentiary hurdle for plaintiffs. The decision prevents a flood of emotional distress claims in routine breach of contract cases by requiring a showing that the contract was for more than just a pecuniary or practical purpose. Future litigation in this area will turn on the factual determination of whether a buyer's non-commercial motive for a purchase was significant enough to put the seller on notice of potential nonpecuniary losses.
