Case Law Update: Falance v. FCA US — Court Orders FCA to Answer Warranty Discovery and Pay Motion Fees

A federal magistrate judge in New Mexico has ordered FCA US LLC to fully answer a plaintiff's discovery requests in a Magnuson-Moss Warranty Act lawsuit, make four of its employees available for deposition, and pay the reasonable expenses, including attorney's fees, of the plaintiff's motion to compel. In Falance v. FCA US LLC, No. 1:26-cv-00185 (D.N.M.), plaintiff Victoria Falance sued FCA US, the U.S. maker of Chrysler, Dodge, Jeep and Ram vehicles, under the federal Magnuson-Moss Warranty Act. On October 16, 2026, U.S. Magistrate Judge Jennifer M. Rozzoni granted the plaintiff's motion to compel (Doc. 41); the order resolves only a discovery motion and does not decide the warranty claim itself.

What happened in discovery

According to the court's order, the plaintiff served a first set of interrogatories and requests for production on April 8, 2026. FCA US responded on May 8, 2026, but the court described those responses as "plainly insufficient." FCA US raised the same non-specific objection to all twenty-four interrogatories, that each sought information "neither relevant nor reasonably calculated to lead to the discovery of admissible evidence or proportional to the needs of this case." It made that objection even to Interrogatory No. 1, which asked for the names of "each person answering this set of discovery requests". On the document requests, FCA US said it "will produce" responsive documents but, per the order, produced none.

The order also recounts that the plaintiff's counsel asked for deposition dates for four FCA US employees beginning April 14, 2026, followed up on April 22 and May 1, and sent a formal good-faith letter on May 11. FCA US agreed to supplement its discovery responses but, the court wrote, "did not fulfil its promise," and had not provided the deposition dates when the plaintiff filed the motion.

The plaintiff filed the motion to compel on June 11, 2026. The court granted FCA US an extension to respond until June 30, over the plaintiff's objection, but FCA US did not file a response. On July 30, the court ordered FCA US to show cause why the motion should not be granted in full. FCA US's response attributed the missed filing to "inadvertent delay in the communication of responsive information" and asked for more time; the court found it did not explain why the motion should not be granted.

What the court held

Boilerplate objections were waived. The court wrote that "[b]oilerplate, generalized objections are inadequate and tantamount to not making any objection at all." Despite the lack of briefing, the court reviewed each objection, found none sufficiently specific, and held that FCA US waived its objections to both the interrogatories and the requests for production. The court also applied the New Mexico federal court's local rule that failing to respond to a motion "constitutes consent to grant the motion."

Depositions and a deadline. FCA US must serve full supplemental responses and propose deposition dates for the four employees by November 13, 2026, though the order lets the parties agree to extend the supplemental-response deadline without a court order, and excuses any witness the plaintiff stops seeking to depose.

Fees under Rule 37. When a motion to compel is granted, Federal Rule of Civil Procedure 37(a)(5)(A) says the court "must" order the responsible party to pay the movant's reasonable expenses, including attorney's fees, unless an exception applies. FCA US argued a fee award would be unjust because the issue was "the omission of a single brief, not a pattern of obstruction." The court disagreed, finding that FCA US failed to respond to the motion, failed to adequately show cause, failed to keep its commitments to opposing counsel, and served inadequate initial responses, which "cost Plaintiff meaningful time and expense."

No bad-faith sanctions. The court said it did "not believe that Defendant is engaging in intentional obstruction." It found no evidence of bad faith, declined to impose sanctions beyond the Rule 37 expense award, declined to shift the costs of the delayed depositions, and quashed its order to show cause.

What this means if you have a vehicle warranty claim

This is a single discovery order from a federal magistrate judge in New Mexico. It does not bind Florida courts, does not decide whether any vehicle was defective, and does not predict how this or any other case will end. It does illustrate practical points for warranty claimants:

• Discovery is where warranty cases are often built. In general, much of the evidence about a vehicle's repair history and a manufacturer's warranty handling sits with the manufacturer. Federal rules require objections to be stated with specificity, and this court treated generic objections as no objection at all.
• Document your own good-faith efforts. The court's order recounts a dated record of the plaintiff's emails, follow-ups and a formal good-faith letter. Rule 37 bars a fee award where the movant did not first try in good faith to get the discovery without court action.
• Keep your own records from day one. Repair orders, dates, mileage, and written complaints to the dealer or manufacturer remain important evidence.

For how protection plans differ from a manufacturer's warranty, see What Is a Vehicle Service Contract? More court rulings are collected on our Case Law & Industry Insights page.

Case details

• Case: Victoria Falance v. FCA US LLC
• Court: U.S. District Court for the District of New Mexico
• Case number: 1:26-cv-00185-JCH-JMR (filed January 28, 2026; Magnuson-Moss Warranty Act, 15 U.S.C. § 2301)
• Ruling: Order Granting Plaintiff's Motion to Compel (Doc. 41), entered October 16, 2026, by U.S. Magistrate Judge Jennifer M. Rozzoni
• Next dates: supplemental responses, deposition dates, and the plaintiff's fee petition due November 13, 2026; FCA US's objections to the fee amount due December 4, 2026 (the order lets the parties extend the supplemental-response deadline by agreement)

This article summarizes a court ruling for general informational purposes as of October 18, 2026, and is not legal advice. Reading it does not create an attorney-client relationship. If you have a dispute over a vehicle warranty or service contract, Louis Law Group offers a free case evaluation.