On July 17, 2025, the U.S. District Court for the Central District of California issued a ruling in Sivakova v. American Honda Motor Co., addressing whether plaintiffs had adequately pleaded a claim under Massachusetts General Laws Chapter 93A, Section 9. While the defendant succeeded in narrowing several claims, the Court ultimately allowed the Chapter 93A claim to proceed to discovery. The decision illustrates the challenges defendants face in defeating Chapter 93A claims early, especially when plaintiffs allege product defects with potential safety implications.

Central to the court’s reasoning was the Massachusetts Supreme Judicial Court’s decision in Iannacchino v. Ford Motor Co. (2008), which established an important standard for pleading Chapter 93A claims. Where a plaintiff does not allege personal injury or property damage to themselves or others, the complaint must identify an independent legal standard that the product was at least implicitly represented as meeting but failed to satisfy. This requirement has been used by defendants to challenge speculative defect claims at the pleading stage. In this case, the defendant invoked Iannacchino in its motion to dismiss, arguing that the plaintiffs’ defect allegations did not identify any such independent standard.

To overcome this hurdle, the plaintiffs amended their complaint to allege that the defendant’s products were at least implicitly represented as meeting the independent standard set forth by the federal Transportation Recall Enhancement, Accountability, and Documentation (TREAD) Act. This approach was previously recognized by the District of Massachusetts in McCabe v. Ford Motor Co. (2024) as a viable independent legal standard under Chapter 93A.

Coupled with detailed allegations of consumer harm, the court concluded that the amended complaint sufficiently distinguished the case from Iannacchino. The court reasoned that, unlike in Iannacchino, the plaintiffs’ allegations regarding the defect were specific and not merely bare or conclusory. 

Additionally, the plaintiffs alleged that personal injury or property damage had resulted from the alleged defect, even if such injuries or damages were not suffered by the plaintiffs themselves. The court found is persuasive that other courts have interpreted this distinction under Iannacchino as determinative – at least at the pleading stage.

This decision demonstrates that courts generally apply liberal pleading standards to claims of about injury under Chapter 93A, particularly when plaintiffs provide detailed allegations about defects and resultant harm. For both plaintiffs and defendants, the ruling underscores the importance of pleading specificity and the potential for federal standards, such as the TREAD Act, to serve as independent legal standards under Massachusetts consumer protection law.