2023 Ram 2500 Lemon Law Case Study — Montana

Why This Ram 2500 Qualified For A $16,500 Cash And Keep Settlement Under Federal Magnuson-Moss And Montana Warranty Law

The 2023 Ram 2500 is FCA US LLC’s (Stellantis’s) heavy-duty 3/4-ton pickup, sold at a premium specifically because of the work-truck dependability promise that comes with the Ram heavy-duty platform — the Cummins-and-HEMI-anchored brand identity that Ram has built around capability, towing, and job-site reliability. When the automatic transmission has to be replaced wholesale at 22,954 miles — with burnt transmission fluid and metal debris in the pan as the manufacturer’s own diagnostic finding — the nonconformity strikes at every element of use, value, and the work-truck purpose the vehicle was sold to perform.

This case presented several compelling legal factors:

• Montana New Motor Vehicle Warranty Act (Mont. Code Ann. § 61-4-501 et seq.): Montana protects new-vehicle buyers within a two-year-from-delivery / 18,000-mile term of protection. The statute creates a presumption that a reasonable number of repair attempts have been made if the same nonconformity has been the subject of four or more repair attempts, or if the vehicle has been out of service for a cumulative total of more than 30 days by reason of repair. The Ram 2500’s 105 cumulative calendar days out of service exceeds the Montana 30-day threshold by 3.5x — the cumulative-days prong is met more than three times over by the cumulative-day measure alone.
• Single visit exceeds the entire MT prong by itself: Visit 1 (June 25 – October 6, 2025) was 104 calendar days. That one visit, standing alone, clears the Montana 30-day cumulative-out-of-service threshold 3.4x over — before adding the second visit.
• Federal Magnuson-Moss Warranty Act (15 U.S.C. § 2310): Even where the Montana 2-year / 18,000-mile presumption window has expired, federal Magnuson-Moss provides a parallel breach-of-express-written-warranty remedy that operates against the manufacturer for as long as the original new-vehicle warranty is in effect. Ram’s 5-year / 60,000-mile powertrain warranty covered the engine cooling system and the transmission across this entire repair history — the transmission replacement and the water-pump / pulley / fan-clutch cooling-system failures all sit squarely inside the powertrain warranty period and trigger Magnuson-Moss fee-shifting against Stellantis.
• Manufacturer-level admission of internal failure: The most consequential single finding in this file is that Ram’s own authorized dealership documented burnt transmission fluid and a large amount of metal debris in the fluid pan together with stored DTC P1D90 — an internal-failure finding by the manufacturer’s own technicians, recorded in writing on a warranty repair order. The complete transmission, thermal bypass valve, and transmission cooler were replaced at Stellantis’s expense, with a TCM update and TCM Quicklearn procedure to complete the repair. A complete-transmission-replacement at the manufacturer’s direction is itself a manufacturer-level admission of nonconformity that leaves Stellantis no defensible breach-of-warranty position.
• Cascading cooling-system failure: Worn bearings in the idler pulley, tensioner pulley, and water pump pulley — plus excessive play in the viscous fan clutch — all at the same visit, on a heavy-duty pickup at only 22,954 miles, establish a pattern of premature cooling-system component failure that strikes at the engine-cooling and accessory-drive integrity of the vehicle.
• Manufacturer-issued recall: The Steering Column Control Module (SCCM) recall performed at Visit 2 is itself a Stellantis-issued admission that a steering-column electrical-system defect exists on this generation of the Ram heavy-duty platform — another manufacturer-level admission of nonconformity layered on top of the powertrain and cooling-system pattern.
• Substantial impairment of use and market value: A heavy-duty work truck out of service for 104 consecutive days — with a complete transmission replacement on its history — is by any measure substantially impaired in both use and market value. A recorded transmission replacement on a Carfax for a 2023 Ram 2500 materially depresses resale value relative to any clean-history example of the same configuration.
• Federal Magnuson-Moss fee-shifting: Repeated unsuccessful or major warranty repairs on a written-warranty nonconformity trigger 15 U.S.C. § 2310(d)(2) fee-shifting, requiring the manufacturer to pay the consumer’s reasonable attorney fees on a successful claim. Our client paid $0 out of pocket.