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In re Mercedes-Benz Emissions Litigation

ELR Citation: 46 ELR 20188
Nos. 16-88, (D.N.J., 12/05/2016) (Linares, J.)

A district court dismissed a class action lawsuit against an automobile company for allegedly misleading consumers into purchasing certain diesel vehicles by misrepresenting their environmental impact. The class of consumers alleged that the company's advertisements and public statements represented that it sold "the world’s cleanest diesel automobiles" with high fuel economy and ultra-low emissions, but that these statements were false and misleading because the company used "defeat devices" that reduced the effectiveness of the emission control system under normal driving conditions. The class claimed that had the company been truthful in their statements, they would not have purchased or leased the vehicles, or they would have paid substantially less. But the class lacks standing based on the allegations in their complaint. Although the consumers plausibly pled that the products received did not live up to the claims made by the company, they failed to allege that their injuries were fairly traceable to the company's misrepresentations. The complaint referenced a number of specific advertisements throughout the complaint, but it failed to allege that a class member relied on the cited advertisements in deciding to lease or purchase one of the company's vehicles. The court, however, dismissed the case without prejudice, thereby allowing the consumers to amend the complaint.