Massachusetts Judge Denies New Trial in Jeep Defective Headrest Class Action
On August 4, 2025, U.S. District Judge Allison D. Burroughs in Massachusetts rejected a motion for a new trial in a class action lawsuit against Fiat Chrysler Automobiles (FCA US LLC) over allegedly defective Active Head Restraint (AHR) systems in certain Chrysler, Dodge, and Jeep vehicles. The lawsuit, filed by plaintiff Maria Costa, claimed that the AHR systems, designed to prevent whiplash during rear-end collisions, could deploy without warning due to a weak plastic component, posing risks of injury and crashes. The affected vehicles include models such as the 2010-2018 Dodge Journey, 2010-2012 Jeep Liberty, and 2011-2018 Jeep Grand Cherokee, among others.
Case Background
The class action, initiated in February 2020, alleged that FCA and headrest manufacturer Grammer AG were aware of the defect since at least 2010 but failed to issue recalls or warn consumers, instead replacing faulty headrests with equally defective ones. The plaintiffs argued that the defect violated the Massachusetts Consumer Protection Act and sought damages for the cost of repairs, estimated at $1,400 per headrest, potentially totaling $120 million for Massachusetts owners. The AHR’s plastic component, under constant pressure from a spring mechanism, was prone to environmental stress cracking, causing unintended deployments at speeds up to 67 mph with 120 pounds of force, leading to nearly 500 complaints and 71 reported injuries, according to the National Highway Traffic Safety Administration (NHTSA).
In a November 2023 trial, a Boston federal jury found that FCA violated the Massachusetts Consumer Protection Act but determined that the violation did not cause actual damages to class members, awarding zero damages. The plaintiffs sought a new trial, arguing that a juror’s employer was negotiating a deal with FCA’s parent company, Stellantis NV, creating a potential conflict of interest, and that the jury did not hear evidence about a design change from oil-coated to stainless steel pins.
Judge’s Ruling
Judge Burroughs ruled that the juror’s employer’s negotiations with Stellantis did not taint the trial, as the juror disclosed the potential conflict during selection, and no direct financial stake was evident. The judge also found that the evidence presented, including the low deployment rate (less than 1%) and lack of testimony showing injury or loss of vehicle value, supported the jury’s decision not to award damages. The court noted that the plaintiffs’ arguments about excluded evidence, such as the pin material change, did not justify a retrial, as the verdict aligned with the “manifest weight of evidence.” The case, Jason Nuwer, et al. v. FCA US LLC, is now closed pending any further post-trial motions.
Broader Implications
This ruling follows a similar outcome in a Florida federal court in January 2024, where a jury found FCA liable for violating the Florida Deceptive and Unfair Trade Practices Act but awarded no damages due to the low failure rate and minimal consumer impact. The Massachusetts decision highlights the challenges plaintiffs face in proving financial harm in class actions involving low-incidence defects, even when deceptive practices are established. FCA’s refusal to recall the AHR systems or cover repair costs has drawn criticism, with plaintiffs alleging the company concealed the defect to avoid liability.
The case underscores ongoing scrutiny of FCA’s handling of vehicle defects, with other class actions targeting issues like battery fires in Jeep Wrangler and Gladiator models and the “death wobble” in steering systems. For Massachusetts owners, the denial of a new trial limits options for financial recourse, though individual Lemon Law claims or other legal avenues may still be pursued for unresolved vehicle issues.
Disclaimer: Information is based on available reports and may be subject to updates as legal proceedings evolve.