California Lemon Law Demand Letters

Published: December 4, 2025 • Auto Demands, Demand Letters
California Lemon Law Demand Letters | Song-Beverly Consumer Warranty Act Guide

California’s Song-Beverly Consumer Warranty Act provides powerful remedies when your new or certified used vehicle is a lemon. This comprehensive guide explains how to demand a buyback or replacement, when manufacturer’s fees create settlement leverage, and how to maximize your recovery.

When You Have a California Lemon

California’s Song-Beverly Consumer Warranty Act (Civil Code §§1790-1795.8) is one of the strongest lemon laws in the United States. When a manufacturer cannot repair a substantial defect after a reasonable number of attempts, you are entitled to a refund or replacement vehicle. Understanding when and how to demand this remedy is critical to maximizing your recovery. Our automotive demand letter templates can help you draft an effective letter to assert your rights under California law.

What Qualifies as a Lemon?

Under California law, a vehicle is presumed to be a lemon if it meets ANY of the following conditions during the first 18 months or 18,000 miles (whichever comes first):

  • Four or more repair attempts for the same substantial defect affecting use, value, or safety
  • Two or more repair attempts for a defect likely to cause death or serious bodily injury if the vehicle is driven
  • 30 or more cumulative days out of service for repair of any warranty defects

Important: These are presumptions, not absolute requirements. You may still have a lemon law claim even if you don’t meet these exact numbers, especially if the defect is severe and the manufacturer has had a reasonable opportunity to repair it.

What Makes a Defect “Substantial”?

Not every problem with your car triggers lemon law protection. California courts have held that a defect must “substantially impair” the vehicle’s use, value, or safety. Examples include:

Safety-Critical Defects Brake failures, steering malfunctions, airbag warning lights, engine stalling at speed, transmission failures causing sudden acceleration or loss of power.
Drivetrain and Engine Issues Persistent check engine lights, oil consumption, turbocharger failures, hybrid system malfunctions, transmission shifting problems.
Electronic and Infotainment Failures Backup camera or parking sensor failures (safety feature), navigation system complete failures, climate control failures in extreme weather.
Paint and Body Defects Premature paint peeling or bubbling affecting large areas, water leaks into cabin, wind noise from manufacturing defects.
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Defects That May NOT Qualify Minor rattles or squeaks, cosmetic issues that don’t affect function, normal wear and tear, problems caused by modifications or accidents.
The Reasonable Repair Attempt Standard

California law requires that the manufacturer be given a “reasonable number of attempts” to repair the defect. While the presumption thresholds (4 attempts, 2 for safety, 30 days) create strong legal leverage, the actual standard is fact-specific and considers:

  • Severity of the defect: More dangerous defects require fewer repair attempts
  • Number of related problems: Multiple symptoms of the same root cause count as attempts for the same defect
  • Good faith of repair efforts: Repeated “no problem found” or “cannot duplicate” may count toward reasonable attempts
  • Out-of-service time: Extended delays waiting for parts or diagnostic procedures strengthen your case
Federal Magnuson-Moss Warranty Act Backup

In addition to California’s Song-Beverly Act, you may have federal remedies under the Magnuson-Moss Warranty Act (15 U.S.C. § 2301 et seq.). This federal law provides similar protections and can be especially useful if:

  • Your vehicle is outside the 18-month/18,000-mile presumption window but still under warranty
  • You purchased the vehicle out of state but live in California
  • You want to pursue claims in federal court rather than state court

Both laws allow recovery of attorney’s fees, creating strong settlement leverage.

Used Car Lemon Law Protection

California Civil Code §1795.5 extends lemon law protection to certain used vehicles:

Certified Used Vehicle Coverage

If you purchased a certified used car with a manufacturer’s warranty (not just a dealer warranty), you have lemon law rights if:

  • The defect arose during the manufacturer’s warranty period
  • The manufacturer had a reasonable opportunity to repair
  • The defect substantially impairs use, value, or safety

Key distinction: Only manufacturer-backed warranties qualify. Third-party dealer warranties or extended service contracts do not trigger Song-Beverly lemon law protection (though they may create other breach of warranty claims).

What Is NOT Covered
Situations That Defeat Lemon Law Claims
  • Modifications and alterations: Aftermarket parts, performance modifications, or lifted suspensions that cause or contribute to the defect
  • Accident damage: Problems arising from collisions or other impacts, even if poorly repaired by the dealer
  • Abuse or misuse: Off-road damage to a non-off-road vehicle, racing, lack of required maintenance
  • Normal wear items: Brake pads, tires, wiper blades (unless failing prematurely due to defect)
  • Dealer-only warranties: “As-is” sales or dealer-provided warranties without manufacturer backing
When to Send Your Lemon Law Demand Letter

Timing is critical in California lemon law cases. Send your demand letter when:

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You Meet the Presumption You have documented 4+ repair attempts for the same issue, 2+ for a serious safety defect, or 30+ cumulative days out of service.
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Latest Repair Attempt Failed You just picked up the vehicle from another unsuccessful repair, and the problem persists. This shows the manufacturer cannot fix the issue.
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Safety Concern Persists If the defect involves brakes, steering, airbags, or sudden acceleration/stalling, demand immediately after the second failed repair.
Before Warranty Expires Send your demand while the vehicle is still under warranty. If warranty expires during the claim process, you’re generally still protected.
Manufacturer Arbitration Programs

Many manufacturers sponsor arbitration programs, and some require you to use them before filing a lawsuit. California has certified certain programs as meeting state standards, but you should know:

  • You’re not bound by the decision: If the arbitrator rules against you or offers an insufficient remedy, you can still file a lawsuit
  • Manufacturers ARE bound: If the arbitrator orders a buyback or replacement, the manufacturer must comply
  • Timeline matters: Arbitration can take 60-120 days, during which the statute of limitations continues to run
  • Attorney representation is allowed: You can have a lawyer represent you in arbitration, though many consumers proceed on their own
Should You Use Arbitration?

Manufacturer arbitration can work well for straightforward cases with clear documentation. However, if you anticipate the manufacturer will dispute whether the defect is substantial or whether they had adequate repair opportunities, consider consulting a lemon law attorney before entering arbitration. Arbitration creates a record that can complicate later litigation.

Buyback Title Branding

If you accept a buyback, California requires the manufacturer to brand the vehicle title as a “Lemon Law Buyback” before reselling it. This protects future buyers but also means:

  • The vehicle’s resale value is substantially reduced
  • The manufacturer may be motivated to repair and return the vehicle instead of buying it back
  • You cannot later undo the buyback and keep the vehicle
How Refunds Are Calculated

California’s buyback formula is designed to make you whole while accounting for your use of the vehicle:

Total Refund = Purchase Price – Mileage Offset

Mileage Offset = (Miles driven before first repair attempt ÷ 120,000) × Purchase Price

Purchase Price includes: Vehicle purchase price, sales tax, license and registration fees, manufacturer-installed options, finance charges paid to date

Purchase Price does NOT include: Aftermarket accessories, extended warranties, insurance, dealer prep fees (usually)

Example: You bought a car for $40,000 and drove 8,000 miles before the first repair attempt. Your mileage offset is (8,000 ÷ 120,000) × $40,000 = $2,667. Your refund would be $40,000 – $2,667 = $37,333, plus you get back any down payment, and the manufacturer pays off your loan.

How Manufacturers Respond to Lemon Law Demands

When you send a lemon law demand letter, the manufacturer’s response typically follows predictable patterns. Understanding these defenses helps you anticipate pushback and strengthen your position.

Common Manufacturer Defenses

Manufacturers and their attorneys typically assert one or more of the following defenses:

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“The Vehicle Is Fixed Now” The manufacturer claims the most recent repair resolved the issue, so no buyback is owed. Counter this by continuing to document any recurrence and noting that repeated “fixes” that don’t last prove the defect cannot be repaired.
“No Substantial Defect” The manufacturer argues the problem is minor, cosmetic, or within normal specifications. This defense requires them to prove the defect doesn’t substantially impair use, value, or safety.
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“Cannot Duplicate” or “No Problem Found” Repeated repair orders with this notation can actually help your case, showing the manufacturer had opportunities but failed to diagnose and fix the problem.
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“Insufficient Repair Attempts” The manufacturer claims you didn’t give them enough chances. This is weak if you’re within the presumption thresholds (4 attempts, 2 for safety defects, 30 days out of service).
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“Caused by Abuse or Modification” Any aftermarket parts, performance tunes, or evidence of hard use will be scrutinized. This defense is difficult if the defect is clearly a manufacturing issue.
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“Different Issues, Not Same Defect” The manufacturer claims each repair was for a separate problem. Counter with technical evidence showing all symptoms stem from the same root cause.
Settlement Negotiation Tactics

Most lemon law cases settle before trial. Manufacturers use several negotiation strategies:

Cash and Keep Settlement

The manufacturer offers you a cash payment (often $2,000-$10,000) to keep the vehicle and release all claims. This can make sense if:

  • The defect has been genuinely fixed and you’re satisfied
  • You’re outside the presumption period and your case has some risk
  • You want to avoid the time and hassle of a full buyback process

Warning: Carefully evaluate whether the cash amount adequately compensates for diminished resale value, your time and frustration, and the risk the problem will return after the settlement.

Reduced Buyback Offer

The manufacturer offers a buyback but argues for a higher mileage offset or disputes what’s included in the purchase price. Common disputes:

  • Whether registration fees and sales tax are included
  • How to handle trade-in value vs. cash down payment
  • Whether dealer-installed accessories count
  • Calculation of finance charges paid to date

These disputes often come down to negotiation and statutory interpretation. California law generally favors consumers on these issues.

Replacement Vehicle Instead of Buyback

The manufacturer offers a comparable replacement vehicle instead of a refund. This can be attractive if:

  • You like the make and model, just not this particular lemon
  • Current interest rates are higher than your existing loan rate
  • The replacement is truly comparable or better in features and trim

Watch out for manufacturers trying to substitute a lower trim level or model year. The replacement must be truly comparable in value.

When Manufacturers Refuse to Settle

Some manufacturers have policies of forcing lemon law claims into litigation or arbitration, betting that consumers will give up or accept lowball offers. If the manufacturer refuses a reasonable settlement:

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File Arbitration or Lawsuit If your case is strong (meets presumption, clear documentation, no abuse/modification issues), proceeding to formal dispute resolution is often worthwhile, especially with attorney representation.
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Attorney’s Fees Leverage California’s lemon law provides that prevailing consumers recover attorney’s fees and costs. This creates enormous settlement pressure—the manufacturer may face $30,000+ in your attorney’s fees on top of the buyback amount.
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Civil Penalties for Willful Violation If the manufacturer’s refusal is willful (they know you have a valid claim but refuse to honor it), you may be entitled to a civil penalty of up to two times your actual damages.
Do Not Continue Driving an Unsafe Vehicle

If your lemon has a serious safety defect (brakes, steering, airbags, sudden acceleration), do NOT continue driving it just to build your case. Your safety is paramount. Document the defect thoroughly, but do not put yourself or others at risk.

If you must stop driving the vehicle, notify the manufacturer in writing that the vehicle is undrivable due to the safety defect and demand they arrange for towing and a loaner vehicle.

Manufacturer Stalling Tactics

Be prepared for manufacturers to delay resolution through various means:

  • Requesting extensive documentation: Asking for records you’ve already provided, or demanding irrelevant information
  • Scheduling distant inspection dates: Requiring you to bring the vehicle for inspection weeks or months out
  • Offering one more repair attempt: Promising “a new fix from engineering” after multiple failed repairs
  • Claiming review by regional or corporate teams: Stating that various levels of management must approve any buyback

While some delay is inherent in large corporate processes, excessive stalling may support a “willful violation” claim. Document all delays and keep pushing for resolution.

Evidence Checklist for California Lemon Law Claims

Strong documentation is the foundation of every successful lemon law case. The more organized and complete your evidence, the faster you’ll reach a favorable settlement.

Critical Documents (Must Have)
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Purchase Contract and Buyer’s Order Your purchase agreement showing the total purchase price, trade-in value, down payment, financing terms, and all fees and taxes. This establishes the baseline for your buyback calculation.
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ALL Repair Orders Every single repair order from the dealer, even for unrelated issues. Pay special attention to repair orders that mention the defect, note “no problem found,” or show extended out-of-service time.
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Warranty Booklet and Owner’s Manual These documents establish the warranty terms and what’s covered. Make sure you can prove the defect is covered under the manufacturer’s warranty.
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Timeline Log A chronological list of every repair visit, with dates, mileage, days out of service, complaint description, and dealer response. This crystallizes the pattern of failed repairs.
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All Correspondence Emails, texts, and letters with the dealer and manufacturer. Include any promises to fix the problem, acknowledgments of the defect, or settlement discussions.
Supporting Evidence (Highly Recommended)
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Photos and Videos Visual evidence of the defect in action: dashboard warning lights, video of engine misfires, photos of paint defects, recordings of strange noises. Date-stamp everything.
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Independent Inspection Report If you paid for an independent mechanic to diagnose the problem, include their report. This is especially valuable if dealer repair orders say “no problem found.”
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Rental Car and Towing Receipts Documentation of out-of-pocket expenses for rentals while your car was in the shop, or towing costs when the defect left you stranded.
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Call Logs and Notes Record of phone calls with dealer service advisors and manufacturer customer service, including dates, who you spoke with, and what was discussed.
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Technical Service Bulletins (TSBs) and Recalls Search NHTSA’s database and manufacturer forums for TSBs or recalls related to your defect. This proves the manufacturer knows about the problem.
Organizing Your Repair History

Create a clear summary table of all repair attempts for the defect. This makes it easy for the manufacturer (or arbitrator/judge) to see the pattern:

Date Mileage Days Out of Service Customer Complaint Dealer Action Problem Resolved?
3/15/2024 1,847 3 Engine stalls at idle Reflashed ECU, test drive OK No – stalling continued
4/22/2024 3,201 5 Engine still stalling Replaced throttle body No – stalling continued
5/30/2024 4,592 7 Ongoing stalling issue Replaced fuel pump, no problem found on test No – stalling continued
7/8/2024 6,018 12 Engine stalling worsening Awaiting parts from manufacturer, extended diagnostic No – problem persists

This example shows: 4 repair attempts over 4 months, 27 cumulative days out of service, and an ongoing safety-critical defect. This is a strong lemon law case.

What NOT to Include in Your Demand Package
Avoid These Documentation Mistakes
  • Exaggerations or inaccuracies: Claiming 6 repair attempts when you had 4 destroys your credibility. Stick to provable facts.
  • Unrelated complaints: Don’t mix legitimate warranty defects with minor annoyances or normal wear items. Focus on the substantial defect.
  • Evidence of modifications: If you’ve modified the vehicle, don’t highlight this. The manufacturer will use it to argue you caused the defect.
  • Social media rants: Angry Facebook posts or tweets may undermine your credibility and show bias. Keep your demand letter professional.
  • Threats or ultimatums: Don’t threaten to “sue for millions” or “report them to the Attorney General.” State your rights calmly and professionally.
Preservation Notice

In your demand letter, include language directing the manufacturer to preserve all documents, repair records, technical service bulletins, and internal communications related to your vehicle and the defect. This is critical for potential litigation discovery.

Example: “You are hereby directed to preserve all documents, electronic records, repair orders, communications, technical service bulletins, and other materials related to my vehicle (VIN: XXXXX) and the defects described herein. This includes all communications with dealerships, engineers, and customer service representatives.”

Demonstrating the Defect

If possible, offer to demonstrate the defect to the manufacturer’s representative. For intermittent problems, this can be powerful evidence:

  • Video recordings: Capture the defect happening in real-time with date/time stamps visible
  • Passenger witnesses: Have family members or colleagues document experiencing the defect
  • Dealer test drives: Insist that service advisors test drive the vehicle with you to experience the problem firsthand
  • Data logs: Some defects can be proven through vehicle computer logs—ask if the dealer can pull diagnostic data
Common Documentation Gaps and How to Fix Them

Problem: You verbally reported the defect several times but it’s not on early repair orders.

Solution: In your demand letter, note: “I reported the [defect] on multiple occasions starting with my [date] service visit, though the written repair order may not reflect this. The defect first manifested at approximately [mileage].”

Problem: Some repair visits were to a different dealer or an independent shop.

Solution: Gather repair orders from all facilities. Repairs at authorized dealers carry more weight, but independent shop records can support your timeline.

Problem: You didn’t keep all your repair orders.

Solution: Request copies from the dealer service department. Under California law, dealers must maintain repair records and provide copies to customers upon request.

Settlement Ranges and Practical Outcomes

California lemon law cases typically settle before trial, often before a lawsuit is even filed. Understanding realistic outcomes helps you evaluate settlement offers and decide whether to accept or push forward.

Typical Settlement Outcomes

Full Buyback (Most Common for Strong Cases): The manufacturer repurchases the vehicle for the full purchase price minus a mileage offset calculated as (miles before first repair attempt ÷ 120,000) × purchase price. This typically happens when:

  • You meet or exceed the presumption thresholds (4 attempts, 2 for safety defects, or 30 days out of service)
  • The defect is well-documented and clearly substantial
  • You have attorney representation with credible threat of litigation

Replacement Vehicle: The manufacturer provides a comparable new vehicle instead of a refund. This is more common when:

  • You express willingness to accept a replacement during negotiations
  • The manufacturer has excess inventory of comparable models
  • Your defective vehicle can be easily resold after branding

Cash and Keep Settlement: You receive $2,000-$15,000 to keep the vehicle and release all claims. This typically happens when:

  • Your case is borderline (fewer repair attempts, outside presumption period)
  • The defect has been genuinely fixed in recent repairs
  • You prefer quick cash resolution over buyback hassle
Attorney’s Fees: The Biggest Settlement Lever

California Civil Code §1794 provides that prevailing consumers are entitled to recover reasonable attorney’s fees and costs. This creates enormous settlement pressure on manufacturers because:

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Fees Often Exceed Buyback Amount In a case with a $30,000 buyback value, attorney’s fees can easily reach $40,000-$60,000+ through trial. Manufacturers face 2-3x total exposure.
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Fees Are Awarded Even on Settlements If you settle before trial, your attorney can still recover reasonable fees for the work performed. This prevents manufacturers from making lowball offers hoping to avoid fee liability.
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Multiplier for Willful Violations If the manufacturer’s conduct was willful or in bad faith, the court may enhance the fee award. This punishes stonewalling and unreasonable denial of valid claims.
Why Manufacturers Settle Quickly with Represented Consumers

When you hire an experienced lemon law attorney, manufacturers know they face significant fee exposure. A case that might cost them $25,000 in buyback could cost $75,000+ total with attorney’s fees and costs. This is why attorney-represented cases often settle within 60-90 days of the demand letter, while unrepresented consumers may wait months or face lowball offers.

Buyback Calculation Examples
Example 1: New Vehicle, Early Defect

Purchase price: $45,000 (including taxes, fees, and registration)

Miles before first repair attempt: 523 miles

Current mileage: 4,200 miles

Mileage offset: (523 ÷ 120,000) × $45,000 = $196.13

Refund amount: $45,000 – $196 = $44,804

What happens to the loan: The manufacturer pays off your remaining loan balance directly, and you receive the difference between the refund amount and the loan payoff. If you owe $40,000, you’d receive $4,804 in cash.

Example 2: Higher Mileage Before First Repair

Purchase price: $35,000

Miles before first repair attempt: 8,400 miles

Current mileage: 18,000 miles

Mileage offset: (8,400 ÷ 120,000) × $35,000 = $2,450

Refund amount: $35,000 – $2,450 = $32,550

Example 3: Certified Used Vehicle

Purchase price: $28,000 (certified used with manufacturer warranty)

Miles before first repair attempt: 22,400 miles (vehicle had 18,000 miles at purchase)

Current mileage: 31,000 miles

Mileage offset: (4,400 miles driven ÷ 120,000) × $28,000 = $1,026.67

Refund amount: $28,000 – $1,027 = $26,973

Factors That Increase Settlement Value
Safety-Critical Defect Brake failures, steering malfunctions, airbag issues, and sudden acceleration problems command faster and fuller settlements due to litigation risk.
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Attorney Representation Having a lemon law attorney increases average settlement value by 30-50% compared to unrepresented consumers, and dramatically accelerates resolution.
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Exceeding Presumption Thresholds The more repair attempts and out-of-service days beyond the minimum thresholds, the stronger your case and the faster manufacturers settle.
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Clear Documentation Complete repair records, chronological logs, and evidence that the defect persists despite multiple repair attempts eliminate manufacturer defenses.
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Known Defect with TSB If a Technical Service Bulletin exists acknowledging the defect, manufacturers know they cannot claim “no problem” and settle more quickly.
Factors That Reduce Settlement Value
Vehicle Modifications Aftermarket parts, performance tunes, lifted suspensions, or other modifications give manufacturers an “abuse” defense and reduce settlement leverage.
Outside Presumption Period Defects manifesting after 18 months or 18,000 miles face higher scrutiny, though you can still win if the defect arose during the presumption period.
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Sparse Documentation Missing repair orders, gaps in your timeline, or inability to prove the defect substantially impairs use/value/safety weakens settlement position.
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High Mileage Offset If you drove many miles before the first repair attempt, your refund amount decreases, making cash-and-keep settlements more attractive to manufacturers.
Timeline Expectations
Typical Lemon Law Resolution Timeline
  • Demand letter to manufacturer response: 10-30 days
  • Initial settlement negotiations: 30-60 days from demand
  • Buyback processing (if settled): 30-60 days from settlement agreement
  • Arbitration (if required): 60-120 days from filing arbitration request
  • Lawsuit filing to settlement: 4-8 months (most settle before trial)
  • Trial (if case doesn’t settle): 12-24 months from filing

Key takeaway: Attorney-represented cases typically settle within 90-180 days of the demand letter. Unrepresented consumers often face longer timelines and lower settlement offers.

Statute of Limitations

California lemon law claims must be filed within 4 years of the date you discovered (or should have discovered) the defect. However, waiting too long weakens your case practically, even if you’re within the statute of limitations. Send your demand letter as soon as you meet the presumption thresholds or conclude the manufacturer cannot fix the defect.

California Lemon Law Demand Letter Templates

Use these professionally drafted templates as starting points for your lemon law demand letters. Customize with your specific vehicle information, repair history, and demands.

Initial Notice of Nonconformity (First Letter)
[Your Name] [Your Address] [City, State ZIP] [Email] [Phone] [Date] [Manufacturer Name] Customer Relations Department [Manufacturer Address] RE: Notice of Nonconformity – Song-Beverly Consumer Warranty Act Vehicle: [Year Make Model] VIN: [17-Digit VIN] Purchase Date: [Date] Dealership: [Dealer Name and Location] Dear Sir or Madam: This letter constitutes formal notice under California’s Song-Beverly Consumer Warranty Act (Civil Code §§1790-1795.8) that the above-referenced vehicle suffers from a substantial defect that you have been unable to repair after a reasonable number of attempts. DEFECT DESCRIPTION: [Describe the defect specifically: “The engine stalls without warning at idle and low speeds, creating a serious safety hazard in traffic.”] REPAIR HISTORY: I have brought the vehicle to your authorized dealership on the following occasions for repair of this defect: 1. [Date] at [mileage] miles – [Dealer action] – Problem not resolved 2. [Date] at [mileage] miles – [Dealer action] – Problem not resolved 3. [Date] at [mileage] miles – [Dealer action] – Problem not resolved 4. [Date] at [mileage] miles – [Dealer action] – Problem persists The vehicle has been out of service for a total of [XX] days due to these repair attempts. This defect substantially impairs the vehicle’s use, value, and safety. Despite [number] repair attempts, you have been unable to conform the vehicle to the applicable express warranty. I am providing you with this final opportunity to repair the defect. Please contact me within 10 business days to schedule a repair appointment. If you cannot repair the vehicle, I demand that you initiate buyback or replacement proceedings under the Song-Beverly Consumer Warranty Act. You are directed to preserve all documents, repair records, technical service bulletins, and communications related to this vehicle and the defect described herein. I prefer to resolve this matter cooperatively. Please contact me at [phone] or [email] to discuss resolution. Sincerely, [Your Signature] [Your Printed Name] Enclosures: Repair orders, purchase contract
Formal Buyback Demand Letter
[Your Name] [Your Address] [City, State ZIP] [Email] [Phone] [Date] [Manufacturer Name] Customer Relations / Legal Department [Manufacturer Address] RE: DEMAND FOR REPURCHASE – Song-Beverly Consumer Warranty Act Vehicle: [Year Make Model] VIN: [17-Digit VIN] Purchase Price: $[Amount] Purchase Date: [Date] Current Mileage: [Mileage] Dear Sir or Madam: I demand that you immediately initiate repurchase proceedings for the above-referenced vehicle pursuant to California Civil Code §1793.2(d)(2). You have had more than a reasonable number of attempts to repair a substantial defect, and you have failed to conform the vehicle to the applicable express warranty. VEHICLE INFORMATION AND PURCHASE PRICE: Purchase Price: $[Amount] Sales Tax: $[Amount] License/Registration: $[Amount] Down Payment: $[Amount] Trade-In Value: $[Amount] Total Amount Financed: $[Amount] Lender: [Lender Name] DEFECT AND REPAIR HISTORY: [Detailed description of defect and impact on use/value/safety] The vehicle has been to your authorized dealership for repair of this defect on the following occasions: [Create detailed table showing Date, Mileage, Days Out of Service, Customer Complaint, Dealer Action, and Outcome for each repair attempt] TOTAL REPAIR ATTEMPTS: [Number] TOTAL DAYS OUT OF SERVICE: [Number] PRESUMPTION OF REASONABLE REPAIR ATTEMPTS: This case meets California’s statutory presumption of a reasonable number of repair attempts because [select applicable]: ☐ The vehicle has been subject to four or more repair attempts for the same nonconformity ☐ The vehicle has been subject to two or more repair attempts for a defect likely to cause death or serious bodily injury ☐ The vehicle has been out of service for more than 30 cumulative days DEMAND FOR REPURCHASE: Pursuant to Civil Code §1793.2(d)(2), I demand that you: 1. Repurchase the vehicle for the full purchase price of $[amount], less the mileage offset calculated pursuant to Civil Code §1793.2(d)(2)(C): [miles before first repair ÷ 120,000 × purchase price]; 2. Refund my down payment of $[amount]; 3. Pay off the loan balance of approximately $[amount] held by [lender]; 4. Reimburse incidental and consequential damages including rental car costs of $[amount] and towing costs of $[amount]; 5. Pay reasonable attorney’s fees and costs as provided by Civil Code §1794(d). TOTAL ESTIMATED BUYBACK: $[Purchase Price – Mileage Offset] plus payoff of loan balance and incidental damages. DEADLINE AND NEXT STEPS: Please respond in writing within 15 business days with your written commitment to repurchase the vehicle. If you do not agree to proceed with repurchase, I will pursue all available remedies including arbitration and litigation. California law entitles prevailing consumers to recover attorney’s fees and costs. Additionally, if your refusal to honor this legitimate claim is found to be willful, I may be entitled to a civil penalty of up to two times my actual damages pursuant to Civil Code §1794(c). You are directed to preserve all documents, communications, repair records, technical service bulletins, and other materials related to this vehicle and the defect described herein. I prefer to resolve this matter promptly and professionally. Please contact me at [phone] or [email] to arrange the repurchase. Sincerely, [Your Signature] [Your Printed Name] Enclosures: All repair orders, purchase contract, warranty documentation, repair timeline summary
Demand Letter – Certified Used Vehicle
[Your Name] [Your Address] [City, State ZIP] [Email] [Phone] [Date] [Manufacturer Name] Certified Pre-Owned Program [Manufacturer Address] RE: Lemon Law Claim – Certified Used Vehicle Vehicle: [Year Make Model] VIN: [17-Digit VIN] Purchase Date: [Date] Certification Date: [Date] Manufacturer Warranty: [Yes/Active] Dear Sir or Madam: I purchased the above-referenced certified used vehicle on [date] from [dealer name]. The vehicle was sold with your manufacturer-backed certification and warranty. I am writing to demand a repurchase under California’s Song-Beverly Consumer Warranty Act, Civil Code §1795.5. CERTIFIED USED VEHICLE LEMON LAW COVERAGE: California Civil Code §1795.5 extends lemon law protection to used vehicles sold with a manufacturer’s warranty. This vehicle qualifies because: 1. It was sold as a manufacturer-certified used vehicle 2. It carries your manufacturer-backed warranty (not merely a dealer warranty) 3. The defect arose during the warranty period 4. You have had a reasonable opportunity to repair the defect DEFECT AND REPAIR HISTORY: [Describe defect and repair attempts, following format from previous template] DEMAND: I demand repurchase of the vehicle for the full purchase price of $[amount] less the mileage offset calculated from the date of my purchase, plus payoff of my loan balance and reimbursement of incidental damages. The calculation is identical to new vehicle lemon law claims: The mileage offset is based on miles I drove before the first repair attempt, not the vehicle’s total mileage. Please respond within 15 business days to arrange the repurchase. Sincerely, [Your Signature] [Your Printed Name]
Repair Attempt Summary Table (Include in Demand Letters)
REPAIR ATTEMPT SUMMARY FOR [YEAR MAKE MODEL], VIN: [VIN] | Date | Mileage | Days O/S | Customer Complaint | Dealer Action | Resolved? | |————|———|———-|———————————————|—————————————-|———–| | 01/15/2024 | 1,203 | 2 | Check engine light, rough idle | Reflashed ECU, test OK | No | | 02/28/2024 | 2,847 | 4 | Check engine light returned, stalling | Replaced oxygen sensor | No | | 04/10/2024 | 4,201 | 6 | Engine stalling at idle, CEL on | Replaced fuel injectors, ECU update | No | | 05/22/2024 | 5,688 | 8 | Continued stalling, now stalling at speed | Awaiting engineering guidance | No | | 07/01/2024 | 7,104 | 11 | Dangerous stalling at highway speeds | Replaced throttle body, still testing | No | TOTAL REPAIR ATTEMPTS: 5 TOTAL DAYS OUT OF SERVICE: 31 days PRESUMPTION MET: Yes – exceeds both 4 repair attempts and 30 days out of service thresholds Miles driven before first repair attempt: 1,203 Mileage offset calculation: (1,203 ÷ 120,000) × $[Purchase Price] = $[Offset Amount]
Response to Lowball Settlement Offer
[Your Name] [Your Address] [Date] [Manufacturer Representative] [Manufacturer Name] RE: Response to Settlement Offer – VIN [VIN] Dear [Name]: I received your settlement offer of $[amount] to retain the vehicle and release all claims. While I appreciate your willingness to negotiate, this offer does not adequately compensate me for the defect and my rights under California law. My vehicle qualifies for a full repurchase under the Song-Beverly Consumer Warranty Act. The appropriate remedy is: Repurchase Amount: $[Purchase Price] – $[Mileage Offset] = $[Net Refund] Loan Payoff: $[Amount] Incidental Damages: $[Rental/Towing Costs] Your offer of $[amount] represents only [X]% of the statutory buyback amount and does not account for: 1. The vehicle’s diminished resale value due to the defect history 2. My time and frustration through [X] failed repair attempts 3. The safety risk I have endured 4. My potential attorney’s fees claim under Civil Code §1794(d) I am willing to consider a cash-and-keep settlement if you increase your offer to $[amount], which represents a reasonable compromise accounting for the diminished value and my inconvenience. Alternatively, I request that you proceed with the full statutory repurchase as demanded in my [date] letter. Please respond within 10 business days. Sincerely, [Your Signature] [Your Name]
Preservation of Evidence Language (Include in All Demand Letters)
PRESERVATION OF EVIDENCE DIRECTIVE: You are hereby directed to immediately preserve and retain all documents, electronic records, communications, and other materials related to: 1. This vehicle (VIN: [VIN]) including all repair orders, service records, diagnostic reports, warranty claims, internal communications, and customer service notes; 2. The defect described herein, including all technical service bulletins, engineering reports, field reports, customer complaints, recall investigations, and internal analyses related to [describe defect]; 3. All communications with dealerships, customer service representatives, technical staff, and legal personnel regarding this vehicle and my claim; 4. All policies, procedures, and guidelines related to Song-Beverly Consumer Warranty Act claims, buyback evaluations, and settlement authority. This preservation directive applies to all forms of records including paper documents, emails, text messages, database entries, voice recordings, and any other medium. Failure to preserve these materials may result in spoliation sanctions in any future litigation.
How I Handle California Lemon Law Cases

I represent consumers in California lemon law cases throughout the state. My practice focuses on maximizing your recovery while minimizing your hassle and out-of-pocket costs.

My Approach to Lemon Law Representation

Case Evaluation: I start by reviewing your purchase documents, all repair orders, and warranty information to assess whether you have a strong lemon law claim. I look for the presumption thresholds, evaluate the substantiality of the defect, and identify any manufacturer defenses.

Demand Letter and Negotiation: I draft a comprehensive demand letter that establishes your legal rights, quantifies the buyback amount, and creates settlement pressure through the attorney’s fees provision. Most of my cases settle within 60-90 days of the demand letter because manufacturers know they face significant fee exposure if they force litigation.

Arbitration and Litigation: If the manufacturer refuses reasonable settlement, I handle arbitration (if required) or file a lawsuit in California Superior Court. I take cases through trial when necessary, though most settle before trial once the manufacturer faces depositions and discovery costs.

Maximum Recovery: My goal is to secure the full statutory buyback (purchase price minus fair mileage offset) plus reimbursement of your incidental costs, and to recover my attorney’s fees from the manufacturer rather than from your recovery.

Fee Structures for Lemon Law Cases
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Contingency Fee Representation For strong lemon law cases (clear presumption, good documentation, no modification/abuse issues), I typically work on contingency. You pay nothing upfront, and my fee comes from a percentage of your recovery or from the manufacturer’s payment of attorney’s fees under Civil Code §1794(d). This aligns my interests with yours—I only get paid if you win.
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Hybrid Fee Arrangements For cases with some risk (borderline facts, outside presumption period, sparse documentation), I may propose a hybrid arrangement with a reduced contingency percentage plus recovery of attorney’s fees from the manufacturer if we prevail.
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Demand Letter Only Services If you prefer to handle negotiations yourself but want a professionally drafted demand letter, I offer flat-fee demand letter preparation. This includes case evaluation, document review, and drafting a detailed statutory demand letter. Fees typically range from $1,500-$3,500 depending on complexity.
Why Attorney Representation Matters in Lemon Law Cases

California’s attorney’s fees provision creates a unique dynamic: manufacturers face potentially unlimited fee exposure if they deny a valid claim and force litigation. When I represent you, manufacturers know they cannot simply wait you out or make a lowball offer hoping you’ll give up.

Data shows that attorney-represented lemon law claimants recover 30-50% more on average than unrepresented consumers, and cases settle 2-3x faster. The manufacturer pays my fees separately, so you typically receive your full buyback amount without any deduction for legal fees.

What to Expect When You Hire Me
Initial Consultation and Document Review

After you contact me, I’ll ask you to send:

  • Your purchase contract and buyer’s order
  • All repair orders (even for unrelated issues)
  • Warranty documentation
  • Any correspondence with the dealer or manufacturer
  • A brief timeline of the defect and repair attempts

I review these documents to assess claim strength, identify the best legal theories, and determine whether I can take your case on contingency or what fee structure makes sense.

Demand Letter and Settlement Negotiation (60-90 Days)

Once retained, I draft and send a detailed statutory demand letter to the manufacturer. The letter:

  • Establishes your rights under the Song-Beverly Consumer Warranty Act
  • Documents the repair history and defect
  • Calculates the precise buyback amount
  • Warns of attorney’s fees and civil penalty exposure
  • Provides a deadline for response and settlement

Most manufacturers respond within 30 days, either offering settlement or requesting additional documentation. I handle all negotiation and push for full statutory recovery.

Arbitration or Litigation (If Necessary)

If the manufacturer refuses fair settlement, I file arbitration (if required by your purchase contract) or lawsuit in California Superior Court. This phase involves:

  • Formal pleadings and discovery (document requests, depositions)
  • Vehicle inspection by manufacturer’s expert
  • Motion practice and settlement conferences
  • Trial preparation (most cases settle before trial)

Timeline: 6-12 months from filing to trial date, though most settle within 4-6 months once discovery begins.

Schedule a Lemon Law Case Evaluation

If you believe you have a California lemon law case, I can help you evaluate your options and determine the best strategy for maximum recovery. Use the Calendly link below to schedule a case evaluation call, or email me directly at owner@terms.law with your repair history and vehicle details.

Schedule Lemon Law Consultation
Frequently Asked Questions

California creates a legal presumption that the manufacturer had a reasonable opportunity to repair if: (1) four or more repair attempts for the same defect, (2) two or more attempts for a serious safety defect likely to cause death or serious injury, or (3) the vehicle is out of service for 30 or more cumulative days. However, you may still have a valid claim with fewer attempts if the defect is severe and the manufacturer clearly cannot fix it.

Repair attempts at the manufacturer’s authorized dealerships carry the most weight. However, repairs at independent shops can still support your timeline and prove the defect exists, especially if the dealer was unable to fix the problem and you sought help elsewhere. For the statutory presumptions, dealership repair attempts are what count.

Yes, unless the defect is a serious safety issue (brakes, steering, airbags). If it’s unsafe to drive, notify the manufacturer in writing that the vehicle is undrivable and demand a loaner. For non-safety defects, you can continue driving, but the miles you accumulate will factor into the mileage offset calculation if you ultimately get a buyback.

Lemon law protections apply equally to financed, leased, and cash purchases. For financed vehicles, the manufacturer pays off your loan and refunds the difference between the buyback amount and the loan balance. For leased vehicles, the manufacturer must make you whole for all payments made, and you’re not liable for remaining lease payments or the residual value.

With attorney representation, most cases settle within 60-120 days of the initial demand letter. If arbitration is required, add 60-90 days. If litigation is necessary, expect 6-12 months from filing to resolution, though most settle before trial. Unrepresented consumers often face longer timelines and more delays.

You receive the full purchase price (including tax, title, license fees) minus a mileage offset based on miles driven before the first repair attempt. The formula is: (miles before first repair ÷ 120,000) × purchase price. If you drove very few miles before the defect appeared, the offset is minimal. Additionally, the manufacturer pays off your loan, reimburses incidental costs (rentals, towing), and pays attorney’s fees separately.

Your down payment is fully refunded as part of the buyback. Your monthly payments are factored into the loan payoff—the manufacturer pays off the remaining loan balance, and you receive the difference between the net buyback amount and the payoff. You don’t lose the payments you’ve already made; they’ve reduced your loan balance, which affects how much cash you receive at buyback.

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