“The Class Vehicles had defective part(s) that increase the risk of a fire spontaneously starting, including when the vehicle is parked and not in use. Currently, it is believed that the defective component in the Class Vehicles is the power steering pump electrical connector.”

💡 This establishes the specific defect and the extraordinary danger it poses even when vehicles are not being driven.

“FCA knew or reasonably should have known about the Fire Defect through sources unavailable to consumers, including pre-market testing (including thermal stress tests and component durability assessments), reports from FCA service centers, and other, aggregate post market data from FCA dealers about the Fire Defect in the Class Vehicles.”

💡 This demonstrates FCA had multiple internal sources of information about the defect that consumers could never access.

“FCA concealed the existence of the Fire Defect and its attendant hazards from the Plaintiff and Class Members at the time of sale or lease. The Defendant has not issued a recall to remedy the Fire Defect.”

💡 This establishes that FCA not only knew about the defect but actively hid it from buyers and still has not recalled the vehicles.

“Federal law requires FCA to monitor defects which can cause safety issues and report them within 5 days. FCA regularly monitors NHTSA complaints in order to meet its reporting requirements under federal law.”

💡 This shows FCA had legal obligations to report the defect that it allegedly failed to fulfill despite knowing about the fires.

“According to the Office of Defects Investigation, 9 Vehicle Owner Questionnaire reports, including 1 Death and Injury Report, and multiple field reports alleging incidents of engine compartment fires in model year 2021-2023 Jeep Wrangler and Gladiator vehicles were made, dating back to as early as March 2021.”

💡 This confirms at least one death resulted from these fires and that FCA knew about the problem since March 2021.

“If they had known about the Fire Defect at the time of sale or lease, Plaintiff and the other Class Members would not have purchased or leased the Class Vehicles or would have paid less for them.”

💡 This establishes the direct economic harm: consumers paid full price for vehicles they would have rejected if properly informed.

“When it comes to your well-being on the road, Jeep Gladiator is ready and willing to stand as a constant Guardian. Gladiator envelopes you with more than 80 standard and available safety & security features, sensors and cameras keep watch around your perimeter to help provide peace of mind.”

💡 This marketing language directly contradicts FCA’s alleged concealment of a defect that could cause vehicles to burst into flames.

“The majority of reports describe a fire occurring while the ignition in the vehicle was in an ‘OFF’ state with a suspected origin at the passenger front side of the engine compartment. It has been reported that at least one fatal accident was caused by a vehicle fire due to the Fire Defect. It is also reported that the fires have caused total vehicle loss and occur without warning.”

💡 This confirms the fires happen without any advance warning, giving owners no opportunity to protect themselves or their property.

“Bettenhausen called the Plaintiff back and informed her that there was no reason to bring the Jeep Wrangler in for inspection or repairs relating to the Fire Defect because ‘it was not part of the recall’.”

💡 This shows that even when consumers proactively sought help, FCA’s dealer network provided no assistance because there was no recall for this known defect.

“According to the ODI, the estimated population of affected vehicles is 781,459.”

💡 This federal estimate establishes the massive scale of potential danger affecting nearly 800,000 vehicles on American roads.

“Many complaints mentioned the vehicle catching on fire out of the blue while driving or parked. In one case, the fire occurred six hours after the car was parked and turned off. In another case, the car spontaneously burned to the ground while parked next to [the] house.”

💡 This demonstrates the fires can occur long after parking, threatening homes and neighborhoods when owners believed their vehicles were safely parked.

“OUR 2021 JEEP STARTED SMOKING IN THE ENGINE AND WITHIN 10 MINUTES BURST INTO FLAMES. THE ENTIRE FRONT END WAS DAMAGED BEYOND REPAIR / BURNED AND FIRE STATIONS HAD TO PUT OUT THE FIRE. MY DAUGHTER, DOGS AND I WERE ABLE TO MAKE IT OUT OF THE CAR BUT VERY SCARY.”

💡 This firsthand account illustrates the terrifying speed at which these fires develop and the risk to families.

“We have over $60,000 in damages to our home, driveway, landscaping and soil (PFAS) from the fire, NOT including the jeep itself.”

💡 This shows the fire hazard extends beyond vehicle loss to cause massive property damage and environmental contamination.

“My 2021 Jeep Wrangler with 1900 miles caught on fire and was a total loss, preliminary investigation believes the cause of the fire to be a gas leak. There were no indications of warning lights, saw black smoke coming from the engine compartment by the time I pulled over and got out of the vehicle it was on fire and within minutes the entire car was engulfed by flames and it was a total loss.”

💡 This demonstrates the defect can manifest in nearly new vehicles with minimal use, proving it is not a wear-and-tear issue.

“My 2022 Jeep Gladiator burned to the ground with 2,500 miles. Jeep sent out their fire investigator and they said it was not a manufacture defect on their part. Allstate sent out their fire investigator and he said it WAS a Jeep manufacturer issue. Both Jeep and Allstate denied to give me copies of the report findings.”

💡 This reveals how FCA’s own investigators denied manufacturing defects even when independent insurance investigators reached opposite conclusions.