Kirzhner v. Mercedes-Benz USA, LLC

Summary

The court held that vehicle registration renewal and nonoperation fees are not recoverable as collateral charges under the Song-Beverly Consumer Warranty Act because they do not supplement the vehicle's purchase or lease price. Those fees may nevertheless be recoverable as incidental damages when incurred after the manufacturer's duty to promptly provide restitution or a replacement vehicle arises and the fees were caused by the manufacturer's delay. The court reversed and remanded because the existing record did not establish when Mercedes's duty arose or whether its delay caused the claimed fees.