Plaintiff brings this lawsuit on behalf of a proposed class of consumers who purchased or leased 2011-2012 Charger vehicles in California claiming the headlight harnesses that Chrysler factory-installed in 2011-2012 Dodge Chargers are defective. A headlight harness is a set of wires that connects the vehicle’s headlight bulbs to its electrical system. In March 2012, Chrysler recalled the headlight harnesses in the 2011 and 2012 Dodge Charger police vehicles. The recall notice stated that the headlight harnesses connectors melt, causing the vehicle’s headlights to fail. The recall notice also stated a recall was necessary because a “loss of headlamps during nighttime driving could cause a crash without warning.”
As in the police vehicles, the headlight harness connectors in the 2011- 2012 Dodge Chargers purchased by Plaintiff and others overheat and melt, causing the vehicles’ headlights to suddenly fail. But Chrysler has not recalled the defective headlight harnesses that it factory-installed in civilian vehicles. Nor has it warned purchasers other than police departments that their vehicle headlights can suddenly fail or that replacing the headlight bulb will not fix the problem. Because Chrysler has not taken any action to remedy the defect in civilian models, Plaintiff and other Charger drivers must pay out of pocket to diagnose and repair the problem.