Mazza v. American Honda Motor Co. (Ninth Circuit)

Several car buyers brought a class action against American Honda Motor Company. The complaint asserted claims for unfair competition, false advertising, and unjust enrichment under California law. We represented Honda in an interlocutory appeal of the district court’s order certifying a nationwide class that included all buyers of the collision mitigation breaking system (“CMBS”) option on certain Acura models. A divided panel of the Ninth Circuit reversed. The panel held that California law could not be applied to all consumer advertising and transactions nationwide merely because Honda was headquartered in California. Rather, the court held, other states’ interests in regulating advertising and consumer transactions within their borders outweighed California’s interest in enforcing its own rules nationwide. The panel also held that not even a single-state class could be certified given the differing communications received by different CMBS buyers at different times and places.