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In O'Connor v. Ford Motor Co., the United States District Court for the Northern District of Illinois addressed whether a Massachusetts Chapter 93A claim could proceed after the court had dismissed the plaintiff's fraud allegations. Ford moved for partial judgment on the pleadings, arguing that the Chapter 93A claim was merely derivative of the failed fraud claim and should therefore be dismissed. The court rejected that argument and allowed the Chapter 93A claim to proceed.
The case arises from a putative class action involving Ford F-150 vehicles from model years 2017 to 2020, which plaintiffs alleged were equipped with defective 10-speed automatic transmissions. The Massachusetts class representative alleged that he experienced transmission slipping and jerking after purchase and that dealership repair efforts did not resolve the issue. He further alleged that Ford failed to disclose known transmission issues and that he would not have purchased the vehicle, or would have paid less for it, had he known of the alleged defect.
Although the court had previously dismissed the plaintiff's fraud claim, it concluded that the Chapter 93A claim was not necessarily coextensive with that theory. Accepting the plaintiff's allegations as true, the court held that the Chapter 93A claim was sufficient to survive a motion for judgment on the pleadings. The court emphasized that the plaintiff was not required to “pin” his claim for relief to any particular legal theory at the pleading stage, nor match his factual allegations to the theories set out in the caption of each count.
This case highlights that Chapter 93A claims are fact dependent and that all reasonable inferences are construed in favor of the pleader at this stage. The court's ruling was limited to whether the allegations at the pleading stage were sufficient to state a claim for relief. The plaintiff is still obligated to develop his theory of liability and establish unfair or deceptive conduct, causation, and injury at summary judgment and/or at trial.
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