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9th Circuit Affirms Hyundai-Kia Settlement Over Vehicle Theft Defects

The U.S. Court of Appeals for the Ninth Circuit affirmed a district court's approval of a class action settlement between consumers and Hyundai Motor Company and Kia Corporation over allegations that certain vehicles were defectively designed and vulnerable to theft. The court rejected an appeal by objector Donald K. Birner in a memorandum opinion filed Jan. 8, 2026.

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Seal of the Ninth Circuit Court of Appeals

Case Information

Case No.:
24-7080

Key Takeaways

  • Ninth Circuit affirmed district court approval of class action settlement over alleged vehicle theft vulnerabilities
  • Objector Donald K. Birner's appeal was rejected by three-judge panel in memorandum opinion
  • Case involved multidistrict litigation proceedings against Hyundai Motor Company and Kia Corporation
  • Court applied standard requiring settlements to be fair, reasonable, and adequate under Federal Rule 23(e)(2)

The U.S. Court of Appeals for the Ninth Circuit affirmed a district court's approval of a class action settlement addressing allegations that certain Hyundai and Kia vehicles contained design defects making them vulnerable to theft. The three-judge panel rejected an appeal by objector Donald K. Birner in a memorandum opinion filed Jan. 8, 2026.

The case, *Plaintiffs' Consumer Class v. Hyundai Motor Company*, arose from a multidistrict litigation proceeding in the U.S. District Court for the Central District of California. District Judge James V. Selna had granted final approval of the class action settlement, prompting Birner's appeal to the Ninth Circuit.

The appeals court panel, consisting of Circuit Judges Kim McLane Wardlaw, Marsha S. Berzon, and Eric D. Miller, heard oral arguments on the matter Nov. 19, 2025, in Pasadena, California. The court issued its decision as an unpublished memorandum opinion, noting that the disposition "is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3."

In its brief opinion, the Ninth Circuit applied the established legal standard for reviewing class action settlements. The court noted that "a class action settlement must be fair, reasonable, and adequate" under Federal Rule of Civil Procedure 23(e)(2). The appeals court reviews district court approval of pre-certification settlements for clear abuse of discretion, citing its 2019 decision in *Roes, 1-2 v. SFBSC Mgmt., LLC*.

The court emphasized the comprehensive review required of district courts, stating that "the district court must show it has explored comprehensively all [Rule 23(e)(2)] factors, and must give a reasoned response to all non-frivolous objections." This language references the court's precedent in *Allen v. Bedolla*, establishing the thorough analysis required when approving class action settlements.

The underlying litigation centered on allegations that certain Hyundai and Kia vehicle models contained design defects that made them particularly susceptible to theft. While the court's memorandum opinion did not detail the specific nature of the alleged defects or the settlement terms, the case was consolidated as part of multidistrict litigation, suggesting it involved widespread claims affecting multiple vehicle owners across different jurisdictions.

Multidistrict litigation procedures are typically employed when numerous similar cases filed in different federal district courts can be efficiently handled together for pretrial proceedings. The Central District of California served as the transferee court for this consolidated litigation, with Judge Selna overseeing the proceedings.

Birner's role as an objector is common in large class action settlements, where individual class members may challenge the proposed terms as inadequate or unfair to class members' interests. Objectors serve an important function in the class action process by providing courts with adversarial testing of proposed settlements before final approval.

The Ninth Circuit's affirmance indicates that Judge Selna properly applied the required legal standards in approving the settlement. Under Rule 23(e)(2), courts must consider whether the settlement was negotiated at arm's length, whether the relief provided is adequate given the costs and risks of continued litigation, whether the settlement treats class members equitably, and whether the settlement was negotiated by experienced counsel.

The court's decision to issue the ruling as a memorandum opinion reflects its view that the case did not present novel legal issues requiring precedential guidance. Memorandum opinions, while not binding precedent, still represent the court's application of established law to specific factual circumstances.

The affirmance allows the settlement to proceed to implementation, providing relief to affected Hyundai and Kia vehicle owners who are part of the consumer class. The specific terms of the settlement, including any monetary compensation, repair programs, or other relief measures, were not detailed in the available court documents.

For automotive manufacturers, the case represents another example of how design defect allegations can lead to significant class action litigation. Vehicle theft vulnerability claims have become increasingly common as thieves develop new methods to exploit security weaknesses in various vehicle models.

The case also demonstrates the efficiency of multidistrict litigation in resolving widespread consumer claims. By consolidating related cases before a single judge, the federal court system can avoid duplicative proceedings while ensuring consistent treatment of similar claims.

With the Ninth Circuit's affirmance, the settlement appears to be final, though the possibility remains for further appeal to the Supreme Court, though such review would be discretionary and unlikely given the case's procedural nature and unpublished status.

Topics

vehicle defecttheft vulnerabilityclass action settlementappellate reviewconsumer protection

Original Source: courtlistener

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