E.D. Tex. Denies Toyota’s Motions to Dismiss and Strike Class Allegations in Door Lock Actuator Defect Case

The lawsuit, Mixon v. Toyota Motor Corporation, centers on allegations that door lock actuators in several Toyota vehicle models unexpectedly cease to function, preventing doors from being locked or unlocked via remote key fobs or interior power switches. Plaintiffs assert that Toyota knew of the defect and deceived consumers to avoid accountability.

Toyota moved to dismiss the case, challenging the viability of the plaintiffs’ civil Racketeer Influenced and Corrupt Organizations Act (RICO) claims and deceptive trade practice claims under Texas law. Toyota also sought to strike the class definitions, arguing they included individuals without standing and that choice-of-law issues would defeat predominance under Rule 23(b)(3).

Judge Mazzant denied the motion to dismiss on standing grounds, holding that unnamed putative class members are not yet subject to dismissal because they have not been certified as part of the class. The court noted that certification is the critical act that renders unnamed members parties to the action.

On the issue of predominance, the court declined to strike the nationwide class definitions at the pleading stage. Judge Mazzant reasoned that determining whether Texas law could be applied nationwide or whether variations in state law would swamp common issues was premature. The court stated it would defer this analysis to the rigorous Rule 23 certification stage.

The court also found that the plaintiffs had stated plausible claims for relief under RICO and the Texas Deceptive Trade Practices Act (DTPA). Toyota’s arguments regarding the pure-economic-loss rule were deemed waived because they were not addressed in the reply brief.

Toyota separately moved for judgment on the pleadings based on statutes of limitations, arguing that the nationwide class included time-barred claims and that four named plaintiffs from specific states had time-barred claims. The court denied this motion as to the named plaintiffs, finding their claims plausible and, in one instance, saved by the relation-back doctrine.

Toyota’s motion to strike the class allegations was denied as moot following the denial of the motion for judgment on the pleadings. The court also denied Toyota’s request for a reply to the defendants’ answers, finding the claims were not meritless enough to warrant such a procedural step.