Breach of Express Warranty as a Cause of Action in California

Breach of express warranty as a cause of action in California applies when a seller or other defendant makes a specific warranty, the plaintiff reasonably relies on it, and the warranty is breached in a way that causes injury. Under Williams v. Beechnut Nutrition Corp., the plaintiff must establish three elements: the exact terms of the warranty, reasonable reliance on that warranty, and a breach that proximately causes injury.

Exact Terms of the Warranty in a California Express Warranty Claim

The first element requires the plaintiff to identify the exact terms of the warranty. A general statement that a warranty existed is not enough. The plaintiff must explain what was actually promised about the product, service, quality, condition, performance, or other subject of the warranty.

The warranty may appear in written materials, product packaging, advertisements, contracts, labels, or other communications. What matters is that the plaintiff can identify the specific representation that formed the basis of the alleged warranty.

This element provides the foundation for breach of express warranty as a cause of action in California. Without knowing the exact promise, it is difficult to determine whether the defendant failed to fulfill it. The terms of the warranty therefore define the obligation that the plaintiff claims was broken.

Reasonable Reliance on the Express Warranty

The second element requires the plaintiff to show reasonable reliance on the warranty. In practical terms, the plaintiff must establish that the warranty influenced the decision to purchase, use, or otherwise act with respect to the product or transaction.

The reliance must also be reasonable under the circumstances. The plaintiff should be able to explain how the warranty affected the decision and why it was reasonable to depend on the representation.

Evidence may include advertisements, product information, written communications, purchase records, or testimony describing what the plaintiff understood and relied upon. This requirement connects the warranty to the plaintiff’s actions and shows that the promise was meaningful to the transaction.

Reasonable reliance is important in a California breach of express warranty claim because the plaintiff must establish more than the existence of an unfulfilled statement. The plaintiff must show that the warranty played a real role in the decision that led to the claimed injury.

Breach of Warranty Causing Injury

The third element requires a breach of the express warranty that proximately causes injury to the plaintiff. A breach occurs when the product, service, or performance does not conform to the specific warranty that was made.

The plaintiff must first show how the defendant failed to satisfy the promised terms. The plaintiff must then connect that failure to the injury being claimed. In other words, the breach cannot merely exist in the abstract. It must have caused the plaintiff’s harm.

Evidence may include product records, photographs, expert findings, repair documents, medical records, financial records, or other materials relevant to the particular injury.

This element completes breach of express warranty as a cause of action in California by linking the broken promise to an actual consequence. If the plaintiff cannot establish that the breach caused injury, the stated test is not satisfied.

Conclusion

Breach of express warranty as a cause of action in California requires proof of three elements. The plaintiff must identify the exact terms of the warranty, establish reasonable reliance on that warranty, and show that a breach proximately caused injury. Each element serves a separate purpose, and the plaintiff must establish all three for the claim to succeed.

Find the Law

“In order to plead a cause of action for breach of express warranty, one must allege the exact terms of the warranty, plaintiff’s reasonable reliance thereon, and a breach of that warranty which proximately causes plaintiff injury. (See Burr v. Sherwin Williams Co. (1954) 42 Cal. 2d 682 [268 P.2d 1041]; Cal. U. Com. Code, § 2313.)” Williams v. Beechnut Nutrition Corp., 185 Cal. App. 3d 135, 142 (1986).