Magnuson-Moss Warranty Act in Maryland

The federal Magnuson-Moss Warranty Act (15 U.S.C. § 2301 et seq.) provides federal-court access and an additional fee-shifting basis for Maryland consumers — overlaying the state Lemon Law § 14-1501 and CPA.

What Magnuson-Moss does

Magnuson-Moss creates a federal cause of action for breach of:

• Written warranties — express manufacturer warranties.
• Implied warranties — merchantability, fitness for particular purpose under state UCC.
• Service contracts — extended warranties.

Manufacturers can be liable for damages, attorney fees, and equitable relief.

§ 2310(d)(2) attorney fees — mandatory

15 U.S.C. § 2310(d)(2) provides:

“If a consumer finally prevails… the court may allow… a sum equal to the aggregate amount of cost and expenses (including attorneys’ fees based on actual time expended)…”

Federal courts treat this as functionally mandatory for prevailing consumers, joining:

• Maryland § 14-1502 fees (discretionary)
• CPA § 13-408(b) mandatory fees

Triple fee-recovery basis in Maryland Magnuson-Moss + Lemon Law + CPA cases.

Federal-court access — D. Md.

Magnuson-Moss provides federal subject-matter jurisdiction where the amount in controversy exceeds $50,000 or the action is a class action with 100+ plaintiffs.

Maryland federal venues:

• D. Md. Northern Division — Baltimore.
• D. Md. Southern Division — Greenbelt. DC-suburb venue, with high-dollar luxury cases.

D. Md. is well-regarded for consumer warranty litigation.

4-year SOL

Magnuson-Moss borrows the state UCC § 2-725 SOL, which Maryland sets at 4 years from delivery under Md. Code Comm. Law § 2-725.

Strategic uses

Maryland lemon-law attorneys typically plead Magnuson-Moss alongside Lemon Law + CPA for these reasons:

1. Federal-court access — D. Md. offers experienced consumer-warranty judges.
2. Triple fee-recovery basis — § 14-1502 + § 13-408(b) + § 2310(d)(2).
3. 4-year SOL runway.
4. Implied warranty claims — useful where express warranty has lapsed.
5. Used vehicle cases — where § 14-1501 doesn’t apply.

Practical workflow

1. Document repair attempts under the express warranty.
2. Send written notice to manufacturer.
3. Complete BBB Auto Line / certified IDS if required.
4. File in D. Md. (if >$50K amount in controversy) or Maryland Circuit Court.
5. Recover under whichever statute provides best damages + fees.

Bottom line

Magnuson-Moss is the federal overlay providing Maryland consumers federal-court access through D. Md., a third mandatory fee-recovery basis, and a 4-year warranty SOL. Pleading all three statutes maximizes recovery options.

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