Minnesota District Court

[COUNTY] Judicial District
State of Minnesota

Court File No.: _____

COMPLAINT

(Lemon Law – Minn. Stat. § 325F.665; Magnuson-Moss Warranty Act, 15 U.S.C. § 2301 et seq.; Breach of Express Warranty)

PLAINTIFF: [PLAINTIFF NAME], an individual Minnesota consumer
v.
DEFENDANT: [DEFENDANT NAME], a [corporation / LLC] duly authorized to do business in Minnesota

[// GUIDANCE: Insert complete legal names, entity types, and registered agent information.]

TABLE OF CONTENTS

1. Parties ....................................................................................................... ¶ 1
2. Jurisdiction & Venue ............................................................................. ¶ 4
3. Statutory Framework & Definitions ...................................................... ¶ 7
4. Factual Allegations ............................................................................... ¶ 15
5. Conditions Precedent / Informal Dispute Resolution ............................ ¶ 25
6. Causes of Action
   Count I – Minnesota Lemon Law ......................................................... ¶ 28
   Count II – Magnuson-Moss Warranty Act ............................................. ¶ 37
   Count III – Breach of Express Warranty (U.C.C.) .................................. ¶ 45
7. Damages & Requested Relief ............................................................... ¶ 52
8. Demand for Jury Trial .......................................................................... ¶ 60
9. Verification (Optional) ........................................................................... ¶ 62
10. Prayer for Relief ................................................................................... ¶ 64
11. Signature Block ................................................................................... p. 15
12. Certificate of Service ........................................................................... p. 16

1. PARTIES

1. Plaintiff [PLAINTIFF NAME] (“Plaintiff”) is a natural person residing at [PLAINTIFF ADDRESS] and is a “consumer” as that term is used in Minn. Stat. § 325F.665, subd. 1(c) and 15 U.S.C. § 2301(3).

2. Defendant [DEFENDANT NAME] (“Defendant”) is a [STATE OF INCORPORATION] [corporation/LLC] with its principal place of business at [DEFENDANT ADDRESS] and is engaged in the manufacture, distribution, or sale of motor vehicles in Minnesota.

3. At all times relevant, Defendant was a “manufacturer” under Minn. Stat. § 325F.665, subd. 1(e).

2. JURISDICTION & VENUE

4. This Court has subject-matter jurisdiction over the Minnesota Lemon Law claim pursuant to Minn. Stat. §§ 8.31 & 325F.665 and supplemental jurisdiction over the Magnuson-Moss and U.C.C. claims.

5. This Court has personal jurisdiction over Defendant because it transacts business and has purposefully availed itself of the Minnesota market.

6. Venue is proper in this County under Minn. Stat. § 542.09 because the transaction and relevant events occurred here and the Vehicle is registered here.

3. STATUTORY FRAMEWORK & DEFINITIONS

7. “Minnesota Lemon Law” means Minn. Stat. § 325F.665 (Motor Vehicle Warranties; Manufacturer’s Duty to Repair; Refund or Replace Vehicle).

8. “Vehicle” means the [YEAR, MAKE, MODEL, VIN] purchased by Plaintiff on [PURCHASE DATE] for personal, family, or household use.

9. “Nonconformity” is any defect or condition that substantially impairs the use, market value, or safety of the Vehicle, as defined at Minn. Stat. § 325F.665, subd. 1(d).

10. “Reasonable Number of Attempts” shall have the meaning set forth in Minn. Stat. § 325F.665, subd. 3.

11. “Purchase Price” means the full contract price paid for the Vehicle, exclusive of interest and finance charges.

[// GUIDANCE: Add or delete definitions consistent with the facts of the case.]

4. FACTUAL ALLEGATIONS

12. On [PURCHASE DATE], Plaintiff purchased the Vehicle from [DEALERSHIP], an authorized dealer of Defendant, for $[AMOUNT].

13. The Vehicle was accompanied by Defendant’s written new-vehicle warranty covering [TERM / MILES].

14. Beginning on or about [FIRST REPAIR DATE], Plaintiff experienced one or more Nonconformities, including but not limited to:
    a. [Describe Defect #1];
    b. [Describe Defect #2];
    c. [Describe Defect #3].

15. Plaintiff tendered the Vehicle for repair on at least [NUMBER] separate occasions and for a cumulative total of [DAYS OUT OF SERVICE] days within the statutory warranty period.

16. Despite Defendant’s attempts, the Nonconformities persist and substantially impair the Vehicle’s use, value, and safety.

17. Plaintiff has complied with all obligations under the warranty, including routine maintenance.

18. Plaintiff provided written notice to Defendant on [NOTICE DATE] demanding refund or replacement pursuant to Minn. Stat. § 325F.665, subd. 4.

19. Defendant has failed, refused, or neglected to provide either a comparable replacement vehicle or refund of the Purchase Price less the statutory usage offset.

5. CONDITIONS PRECEDENT / INFORMAL DISPUTE RESOLUTION

20. Defendant maintains an informal dispute-settlement mechanism purportedly in compliance with 16 C.F.R. Part 703.

21. On [ARBITRATION DATE], Plaintiff submitted the dispute to Defendant’s forum, satisfying the prerequisite set forth in Minn. Stat. § 325F.665, subd. 4(a).

22. The forum issued a decision on [DECISION DATE], which Plaintiff rejected as inadequate.

23. Thirty (30) days have elapsed since the decision, and Plaintiff is therefore entitled to initiate litigation under Minn. Stat. § 325F.665, subd. 4(b).

24. All other conditions precedent to bringing this action have been performed, excused, or waived.

6. CAUSES OF ACTION

Count I – Violation of Minnesota Lemon Law (Minn. Stat. § 325F.665)

28. Plaintiff realleges ¶¶ 1–27.
29. The Vehicle qualifies as a “new motor vehicle” under Minn. Stat. § 325F.665, subd. 1(b).
30. Defendant was afforded a Reasonable Number of Attempts yet failed to conform the Vehicle to the warranty.
31. Under § 325F.665, subd. 3, Defendant is obligated to refund the full Purchase Price or replace the Vehicle.
32. Defendant’s refusal constitutes a statutory violation, entitling Plaintiff to:
    a. Refund or replacement;
    b. Collateral costs (e.g., sales tax, title, registration);
    c. Reasonable attorney’s fees and costs (Minn. Stat. § 8.31).

Count II – Magnuson-Moss Warranty Act (15 U.S.C. § 2301 et seq.)

37. Plaintiff realleges ¶¶ 1–36.
38. The written warranty is a “consumer product warranty” per 15 U.S.C. § 2301(6).
39. Defendant’s failure to remedy Nonconformities constitutes a breach of written and implied warranties.
40. Plaintiff has met the jurisdictional amount (cost or value of remedy exceeds $25).
41. Plaintiff is entitled to all remedies provided under 15 U.S.C. § 2310(d), including costs and reasonable attorney’s fees.

Count III – Breach of Express Warranty (U.C.C.; Minn. Stat. § 336.2-313)

45. Plaintiff realleges ¶¶ 1–44.
46. Defendant’s affirmations of fact, descriptions, and promises relating to the Vehicle created express warranties.
47. The Vehicle failed to conform to these express warranties.
48. Plaintiff duly notified Defendant of the breach as required by Minn. Stat. § 336.2-607(3)(a).
49. Under Minn. Stat. § 336.2-714 and § 336.2-715, Plaintiff is entitled to recover damages measured by the difference at the time and place of acceptance between the value of the Vehicle accepted and the value it would have had as warranted, plus incidental and consequential damages.

7. DAMAGES & REQUESTED RELIEF

52. Plaintiff seeks:
    a. Replacement of the Vehicle with a new, comparable vehicle or a refund of the Purchase Price, less the statutory usage offset based on actual miles driven (usage formula: (miles at first repair ÷ 100,000) × Purchase Price);
    b. Reimbursement of collateral charges (sales tax, license fees, registration, finance charges, towing, rental, etc.);
    c. Incidental and consequential damages;
    d. Statutory costs, disbursements, and reasonable attorney’s fees;
    e. Pre- and post-judgment interest as allowed by law;
    f. Any other relief the Court deems just and equitable.

[// GUIDANCE: Minnesota does not permit punitive damages without leave of court; omit unless later amended.]

8. DEMAND FOR JURY TRIAL

60. Pursuant to Rule 38 of the Minnesota Rules of Civil Procedure and Article I, § 4 of the Minnesota Constitution, Plaintiff demands a trial by jury on all issues so triable.

9. VERIFICATION (Optional – see Minn. R. Civ. P. 11)

62. I, [PLAINTIFF NAME], declare under penalty of perjury that the foregoing facts are true and correct to the best of my knowledge, information, and belief.
    Date: __ ____
    [PLAINTIFF NAME]

10. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests judgment against Defendant as set forth in ¶ 52 above, together with such further relief as the Court finds just and proper.

11. SIGNATURE BLOCK

Dated: _______ Respectfully submitted,

[LAW FIRM NAME]
By: _____
[ATTORNEY NAME], #_
[Address]
[City, State ZIP]
Tel: () -_
Email: [EMAIL]
Attorneys for Plaintiff

12. CERTIFICATE OF SERVICE

I hereby certify that on ______, I served the foregoing Complaint upon Defendant by [personal service / certified mail] in accordance with Minn. R. Civ. P. 4.

[ATTORNEY NAME]

ADDITIONAL GUIDANCE & CUSTOMIZATION NOTES

[// GUIDANCE:
1. Confirm compliance with Minn. R. Civ. P. 5.04 regarding e-filing and service.
2. Review the manufacturer’s arbitration decision; attach as Exhibit A.
3. Attach repair orders chronologically as Exhibit B; keep personal data redacted per Minn. Gen. R. Prac. 11.
4. If financing involved, add lienholder as nominal defendant or address payoff logistics in prayer.
5. Confirm that the statute of limitations (3 years for Lemon Law, 4 years for U.C.C.) has not expired.
6. Replace bracketed placeholders and remove guidance comments before filing.
]

This template is drafted to satisfy Minnesota Lemon Law pleading requirements, integrate mandatory pre-suit arbitration allegations, and preserve a full range of statutory remedies while capping recovery at the vehicle’s Purchase Price, consistent with the liability limits specified.