Niedermeier v. FCA US LLC

Summary

The court held that a consumer's statutory restitution damages under the Song-Beverly Consumer Warranty Act are not reduced by trade-in credit or sale proceeds when the consumer was forced to dispose of the defective vehicle because the manufacturer failed to comply with its statutory obligations. The statutory formula specifies the permissible reductions, and neither the Act's commercial-code remedies nor its labeling provisions authorize an additional offset. The court therefore reversed the Court of Appeal and did not decide whether any offset, if authorized, would be calculated before or after civil penalties.