The Magnuson-Moss Warranty Act

The Magnuson-Moss Warranty Act, codified at 15 U.S.C. §§ 2301–2312, is the federal consumer-warranty statute enacted in 1975 to regulate written warranties on consumer products sold in the United States. It creates a federal cause of action for breach of written or implied warranty and, under § 2310(d)(2), shifts attorney’s fees onto the manufacturer when the consumer prevails. In California lemon law cases, Magnuson-Moss is almost always pleaded alongside the state Song-Beverly Consumer Warranty Act — the federal claim provides an alternate jurisdictional path and a backstop where state coverage is unclear.

 

 

Origins and Purpose

Magnuson-Moss was signed into law in 1975 in response to widespread abuse of “limited” warranties by manufacturers. Before Magnuson-Moss, written warranties on consumer products often disclaimed implied warranties, contained hidden exclusions, and were not enforceable in any practical sense for low-value goods. The Act was authored by Senator Warren Magnuson (D-WA) and Representative John Moss (D-CA).

The statute is administered by the Federal Trade Commission, which issues rules (16 C.F.R. Parts 700–703) interpreting Magnuson-Moss requirements for warranty disclosure, designation as “full” or “limited,” and informal dispute settlement procedures.

 

 

What Magnuson-Moss Covers

Magnuson-Moss applies to any consumer product normally used for personal, family, or household purposes that is sold with a written warranty. The statute does not require manufacturers to issue warranties — but when they do, those warranties must comply with Magnuson-Moss disclosure rules and become enforceable in federal court.

  • New and used motor vehicles sold with a written manufacturer’s warranty
  • Leased vehicles, where a written warranty is provided
  • RVs, motorcycles, and consumer products generally
  • Service contracts sold with consumer products (regulated separately from warranties)

Magnuson-Moss does not apply to commercial products purchased for resale, or to products sold without a written warranty.

 

 

Key Provisions

§ 2301 — Definitions
Defines “consumer product,” “written warranty,” “implied warranty,” and “service contract.” The definitions section determines which products and which warranties fall within the statute.
§ 2302 — Disclosure rules for written warranties
Manufacturers issuing written warranties on consumer products costing more than $15 must make full terms available pre-sale.
§ 2303 — Designation as “full” or “limited”
Written warranties must be designated as “full” or “limited.” A “full” warranty triggers heightened obligations including refund or replacement after a reasonable number of repair attempts.
§ 2308 — Implied warranties cannot be disclaimed when written warranty is given
If a manufacturer issues a written warranty, it cannot disclaim implied warranties (merchantability, fitness for purpose) on the same product. This provision is the federal backstop for state implied-warranty law.
§ 2310(d) — Civil cause of action
Creates the federal private right of action. Subsection (d)(1) permits suit in federal or state court. Subsection (d)(2) provides for the prevailing consumer’s recovery of attorney’s fees and costs.

 

 

Magnuson-Moss vs. Song-Beverly: When Each Applies

For California consumers, both statutes typically cover the same vehicle, but they differ in remedies and procedure:

Feature Magnuson-Moss (federal) Song-Beverly (California)
Cause of action Breach of written or implied warranty Same, plus the lemon presumption
Fee-shifting § 2310(d)(2) § 1794(d) — typically broader interpretation in CA courts
Civil penalty None Up to 2× actual damages for willful violations (§ 1794(c))
Lemon presumption None § 1793.22 — four attempts / 30 days / 18 mo or 18,000 mi
Jurisdiction Federal or state State (CA)
Amount-in-controversy $50,000 for federal court None
Used vehicles Yes if written warranty Yes if manufacturer or CPO warranty

Song-Beverly is the stronger statute for California consumers because of the civil penalty and the lemon presumption. Magnuson-Moss is pleaded alongside as a backstop and to preserve federal venue.

 

 

Why Pleading Both Matters

  • Federal venue option. Magnuson-Moss permits suit in federal court when the amount in controversy exceeds $50,000. Federal court can be advantageous for complex multi-vehicle defects or when the manufacturer has previously litigated similar facts there.
  • Fee-shifting in either court. Both statutes’ fee provisions apply regardless of venue.
  • Implied-warranty backstop. § 2308 incorporates state implied-warranty law and prevents manufacturers from disclaiming implied warranties via the written warranty.
  • “Full” warranty designation. When a manufacturer markets a “full” written warranty, § 2303 triggers stronger refund/replace obligations independent of Song-Beverly.

 

 

Statute of Limitations

Magnuson-Moss has no independent statute of limitations. Federal courts apply the state limitations period for breach of warranty — in California, four years from breach under Commercial Code § 2725. See statute of limitations for lemon law claims.

 

 

Free Lemon Law Case Review

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Frequently Asked Questions

What is the Magnuson-Moss Warranty Act?

The federal consumer-warranty statute, 15 U.S.C. §§ 2301–2312, enacted in 1975. It regulates written warranties on consumer products and creates a federal private right of action with fee-shifting.

Is Magnuson-Moss the same as the California Lemon Law?

No. The California Lemon Law is the Song-Beverly Act, a state statute. Magnuson-Moss is federal and weaker in most respects, but the two are typically pleaded together.

Does Magnuson-Moss have fee-shifting?

Yes — § 2310(d)(2). The manufacturer pays the prevailing consumer’s reasonable attorney’s fees and costs.

Can I sue in federal court under Magnuson-Moss?

Yes, when the amount in controversy exceeds $50,000. Below that threshold, the claim is filed in state court alongside the Song-Beverly claim.

 

 

About the Author

Julian McMillan is the founder of McMillan Law Group and a California lemon law attorney with over 25 years of legal experience, having represented San Diego consumers since 2000. He has been named a Thomson Reuters Super Lawyer twelve consecutive years (2014–2025), recognized by the National Trial Lawyers as a Top 100 Civil Plaintiff Lawyer, and listed in San Diego Magazine’s Top Attorneys in San Diego (2016–2025) and America’s Most Honored Professionals (2018–2025).

Julian holds an L.L.M. from the University of San Diego School of Law, an L.L.M. from Nottingham Law School (England), an L.L.B. with Distinction from the University of Exeter (England), and a B.A. (Honors) from the University of Victoria (Canada). He is admitted to the California Bar, the U.S. District Courts for the Southern, Central, and Northern Districts of California, and the Supreme Court of England and Wales. Before founding McMillan Law Group he practiced at DLA Piper (San Diego) and Ashurst Morris Crisp (London).

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