California consumers are facing new territory now in 2025 under Governor Gavin Newsom’s signing of AB 1755 and notable California Supreme Court decisions.

(PRUnderground) February 24th, 2025

1. Rodriguez v. FCA US, LLC – Limitation of “New Motor Vehicle” Definition

The California Supreme Court in Rodriguez v. FCA US, LLC (2024) significantly narrowed the definition of “new motor vehicle” under the Song-Beverly Act. The court held that a used vehicle with an unexpired manufacturer’s warranty does not qualify as a “new motor vehicle” under §1793.22(e)(2) unless the warranty was issued with the sale.

The court determined that the phrase “other motor vehicle sold with a manufacturer’s new car warranty” only applies to vehicles where the warranty arises from the sale transaction itself, not to previously owned vehicles with remaining warranty coverage. This overturned decades of previous understanding from cases like Jensen v. BMW that had protected used car buyers with remaining factory warranties.

As the court explained: “a motor vehicle purchased with an unexpired manufacturer’s new car warranty does not qualify as a ‘motor vehicle sold with a manufacturer’s new car warranty’ under section 1793.22, subdivision (e)(2)’s definition of ‘new motor vehicle’ unless the new car warranty was issued with the sale.”

2. AB 1755 – Significant Procedural Changes and Limitations

Gov. Newsom’s signing of Assembly Bill 1755 was a further blow to California consumer rights. AB 1755 was entirely rewritten in a last-minute maneuver that caught many consumer advocates off guard. One moment the bill was entirely about child custody; then, two weeks before it was to be voted on in the Senate, it was overhauling critical aspects of California’s Song-Beverly Consumer Warranty Act (aka “the Lemon Law”) that has protected car buyers since 1970.

Assembly Bill 1755, which took effect in 2025, implemented several restrictive changes to California’s lemon law:

1. Shortened Warranty Enforcement: Reduced the timeframe for bringing a lemon law claim from the entire length of the Manufacturer’s warranty to a maximum of 6 years from delivery. Dramatically limiting the enforcement of a Manufacturer’s warranty through the California Lemon Law.
2. Shortened Statute of Limitations: Reduced timeframe for a California consumer to bring a lemon law claim from the expiration of the Manufacturer’s warranty from 4 years to 1 year. This slashing of the statute of limitations incentivizes unscrupulous manufacturers to apply temporary band-aid repairs until the statute of limitations expires 1 year later.
3. Mandatory Pre-Lawsuit Notice: Consumers must now provide detailed written notice to manufacturers before seeking civil penalties, creating new procedural hurdles and shifting the burden historically from the manufacturer to the consumer.
4. Negative Equity Deductions: Manufacturers can deduct negative equity from prior vehicles, significantly reducing refund amounts for many consumers.

Bonus Issue: SB 26 – Currently working its way through the system:

SB 26 further erodes consumer protections by creating a confusing opt-in system where only manufacturers—not consumers—get to choose which legal framework applies to lemon law claims.

While manufacturers who produce the most defective vehicles will likely opt into AB 1755’s restrictive provisions to reduce their liability, consumers have no choice in the matter and must navigate different rules depending on their vehicle’s manufacturer.

This bill perpetuates the anti-consumer shift that began with AB 1755, which was rushed through the Senate and funded by manufacturers, by requiring consumers to provide detailed written notice before seeking remedies and to maintain possession of defective vehicles for specified periods.

Most egregiously, SB 26 forces consumers who sell defective vehicles to provide written notice to buyers about pending lemon law claims, shifting the disclosure burden from manufacturers to consumers and undermining the consumer protection principles that historically defined California’s lemon law.

3. Niedermeier v. FCA US, LLC – Trade-In/Sale Offset Ruling

The California Supreme Court in Niedermeier v. FCA US, LLC (2024) held that manufacturers cannot reduce statutory restitution amounts by trade-in credits or sale proceeds when a consumer has been forced to sell a defective vehicle due to the manufacturer’s failure to comply with the Act.

The court determined that: “neither a trade-in credit nor sale proceeds reduce the statutory restitution remedy set forth in section 1793.2, subdivision (d)(2) at least where, as here, a consumer has been forced to trade in or sell a defective vehicle due to the manufacturer’s failure to comply with the Act.”

These changes mark a major shift in consumer protection rights for California vehicle buyers or lessors. It is crucial that California consumers understand the changes and know their options. 

What the Ruling Means for Car Buyers

Prior to the Rodriguez v. FCA decision, California courts had interpreted the lemon law to cover used vehicles if they were sold with time remaining on the original manufacturer’s warranty. This provided a presumption that entitled buyers to a refund or replacement if warranty defects couldn’t be repaired after a reasonable number of attempts.

Under the new ruling, this presumption no longer applies unless the warranty was issued at the time of the used vehicle sale, such as with certified pre-owned (CPO) vehicles that come with a new warranty from the manufacturer. For used vehicles with only the remainder of the original warranty, buyers will have to use other legal avenues.

Unfortunately, this ruling puts a greater burden on used car buyers to really scrutinize any applicable warranties and understand what is and isn’t covered. It also means buyers need to act quickly and explore their legal options immediately if the vehicle has repeated issues.

What AB 1755 Means for Car Buyers

Prior to the signing of AB 1755 by Gov. Newsom, California vehicle buyers were able to purchase vehicles with the full weight of the law on their side.

They could safely purchase or lease vehicles knowing that if the Manufacturer failed or maliciously decided not to repair their vehicle within their warranty period they could bring a lawsuit. Further, even if the Manufacturer was attempting to fix their vehicle California consumers were protected by a 4-year statute of limitations to bring their lawsuit after the Manufacturer’s warranty had expired.

Now, under AB 1755, regardless if a California consumer receives a vehicle with a 10-plus year warranty (especially common amongst electrical vehicle battery warranties), a consumer is capped by a 6-year statute of limitations beginning at the inception of the warranty. Effectively cutting the enforcement of a vehicle’s Manufacturer warranty under the California lemon law to 6 years, no matter if it was 7, 8, 9, or 10+ year warranty. Additionally, once that reduced Manufacturer’s warranty expires a California consumer has 1 year to bring a lawsuit (rather than the previous 4 years).

The dramatic slashing of the statute of limitations from 4 years to merely 1-year post-warranty creates a ticking time bomb for vehicle owners. This change particularly harms those dealing with intermittent issues or hidden defects that evade consistent diagnosis.

Unethical manufacturers can now implement a calculated strategy: authorize only superficial, temporary fixes during the warranty period, deliberately dragging out the process until your legal window closes. Once the shortened deadline passes, they’re free to identify the actual underlying problem—and demand you pay for the proper repair they avoided making earlier.

This leaves consumers with an impossible choice: absorb repair costs that rightfully belong to the manufacturer or dump their compromised vehicle at a significant financial loss. The compressed timeline effectively rewards deceptive practices while penalizing owners for manufacturer-created problems that take time to fully manifest.

Pursuing Claims Under Federal and State Warranty Laws

While the Rodriguez v. FCA decision limits state lemon law remedies, used car buyers still have important protections under other laws. The federal Magnuson-Moss Warranty Act provides a cause of action for any breach of a written warranty.

Additionally, California’s Song-Beverly Consumer Warranty Act still requires manufacturers to repair warrantied defects and can entitle buyers to a refund or replacement if repairs aren’t completed in a reasonable timeframe.

Although these claims don’t carry the same presumption as a state lemon law case, federal and state warranty laws provide powerful tools to hold manufacturers accountable. The key is for consumers to keep all records and act quickly to pursue a claim as soon as it’s clear they have a lemon on their hands.

What to Do if You Suspect You Have a Lemon

While the changes add new procedural requirements–if you buy a defective vehicle, you still have rights–but it’s more important than ever to consult with an experienced lemon law attorney who can guide you through the process and fight for the compensation you deserve as soon as possible.

Under the new law, car buyers who suspect they have a lemon should:

1. Act quickly: With only a 1-year statute of limitations from the expiration of the Manufacturer’s warranty, pursuing a claim as soon as possible is crucial. Waiting too long could mean losing the right to lemon law relief.
2. Document everything: Keep detailed records of all repair attempts, including dates, mileage, and communications with the dealer or manufacturer. This documentation will be essential for your claim.
3. Provide written notice: Before initiating a lemon law case, you must notify the manufacturer in writing and allow them a final opportunity to repair the vehicle. Your attorney can assist with drafting this notice.
4. Be prepared for mediation: If the manufacturer fails to offer a satisfactory resolution, you’ll need to participate in mediation, arbitration, or file a lawsuit. An experienced attorney can represent your interests in this process.

Seeking Advice from an Experienced Lemon Law Attorney

For New or Certified Pre-owned car buyers dealing with a potential lemon in 2025 after the implementation of AB 1755, the Rodriguez v. FCA ruling, and Niedermeier v. FCA, getting advice from a skilled lemon law attorney is essential. While the process may be more complex, an experienced lawyer can determine the best path forward and fight for the compensation the consumer deserves.

Mission Lemon Law’s lemon lawyers in San Diego, CA are well-versed in state warranty laws and know how to navigate this new legal landscape. Their team is committed to protecting car buyers’ rights and helping them pursue successful claims against manufacturers that fail to uphold their warranties.

New or Certified Pre-Owned car buyers who think they may have purchased a lemon can visit Mission Lemon Law’s website at https://missionlemonlaw.com/ to schedule a free case evaluation with attorney Harrison Bodourian.

About Mission Law Group – Lemon Law

Founded by attorney Harrison Bodourian, Esq., Mission Law Group is a lemon law firm advocating for consumers in the greater San Diego area. The firm’s attorneys have experience handling cases under California’s lemon law as well as state warranty laws.
With a reputation for client advocacy and a track record of successful outcomes, Mission Law Group is dedicated to helping consumers stand up against automotive manufacturers and get the compensation they deserve.

Contact Information:
Harrison Bodourian, Esq.
Contact@MissionLG.com
Mission Law Group
2221 Camino del Rio South
Suite 101
San Diego, CA 92108
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Original Press Release.