Frequently Asked Questions

You received this Notice because you may be a member of the Settlement Class eligible to receive benefits from a proposed settlement of the class action lawsuit Wilson, et al. v. FCA US LLC, Case No. 4:22-cv-00447, currently pending in the United States District Court for the Eastern District of Texas (the “Action”). The Court overseeing the Action authorized this Notice to advise Settlement Class Members about the proposed Settlement that will affect their legal rights. The Notice explains certain legal rights and options you have in connection with that Settlement.

The Action is a proposed class action lawsuit relating to an allegedly defective anti-lock braking system and brake hydraulic control units in certain Ram trucks.

In a class action, one or more representative plaintiffs bring a lawsuit for others who are alleged to have similar claims. Together, these people are the “Class” and each individually is a “class member.” There are eight Plaintiffs (or Representative Plaintiffs) in this case: Jason Wilson, Patrick Krenek, Donald Akridge, Tim VanGee, Leslie Daly, Joseph Bass, James Neu, and Christopher Adams.

Plaintiffs in the Action, through their attorneys, investigated the facts and law relating to the issues in the Action. Plaintiffs and Class Counsel believe that the Settlement is fair, reasonable, and adequate and will provide substantial benefits to the Settlement Class. The Court has not decided whether Plaintiffs’ claims or FCA US’s defenses have any merit, and it will not do so if the proposed Settlement is approved. By agreeing to settle, both sides avoid the cost and risk of a trial, and Settlement Class Members who submit valid claims will receive benefits from the Settlement. The Settlement does not mean that FCA US did anything wrong, or that Plaintiffs and the Settlement Class would or would not win the case if it were to go to trial.

The Settlement Class is defined as all current owners or lessees of a Model Year 2017-2018 DJ Ram 2500 / D2 Ram 3500 / DD Ram 3500 Cab Chassis / DF Ram 3500 10K LB. Cab Chassis / DX Ram Cab Chassis / DP Ram 4500/5500 vehicle built between April 1, 2017 and December 29, 2018. For purposes of this definition, “current owners or lessees” are owners or lessees of a Class Vehicle on or after November 1, 2023.

Excluded from the Settlement Class are FCA US; any affiliate, parent, or subsidiary of FCA US; any entity in which FCA US has a controlling interest; any officer, director, or employee of FCA US; any successor or assign of FCA US; consumers or businesses that have purchased Class Vehicles previously deemed a total loss (i.e., salvage or junkyard vehicles) (subject to verification through Carfax or other means); and any judge to whom the Action is assigned, his or her spouse; and individuals and/or entities who validly and timely opt-out of the settlement.

FCA US has agreed to provide certain benefits to Settlement Class Members under the Settlement. The benefits are as follows:

A. Voluntary Safety Recall

FCA US has instituted a voluntary safety recall, known and numbered as NHTSA Recall No. 24V-896, which provides for the installation of a new Brake HCU component with a pump motor brush material change.

B. Repair Reimbursements

Any Class Member who paid for a repair relating to the replacement of a Brake HCU component will be entitled to submit a Claim for reimbursement to www.fcarecallreimbursement.com. Claims will be paid according to FCA US’s normal recall payment processes.

C. Rental Vehicle Reimbursements

Class Members may submit Claims for rental vehicle reimbursements. FCA US shall pay up to a maximum of $600,000 for claims relating to rental vehicle reimbursements. A Claim for rental vehicle reimbursement cannot exceed $100 per day or a total limit of $1,000 per Class Vehicle. If all claims exceed $600,000 they will be paid on a pro rata basis. To obtain this reimbursement, Settlement Class Members must provide car rental receipts and proof of a contemporaneous repair to the Brake HCU.

Settlement Class Members who do not validly exclude themselves from the Settlement will be bound by the Settlement Agreement and Release (“Settlement Agreement”), and any final judgment entered by the Court, and will give up their right to sue the Releasees for the claims being resolved by the Settlement.

The claims that are being released and the persons and entities being released from those claims are described in the Settlement Agreement. To view the Settlement Agreement, please visit www.fcarambrakesettlement.com.

If you are a Settlement Class Member, you do not have to do anything to remain in the Settlement and receive the benefits of NHTSA Recall No. 24V-896. However, if you want to obtain the reimbursements available to Settlement Class Members under the Settlement, you must complete and submit a Claim Form online at www.fcarecallreimbursement.com.

If you do not want to give up your right to sue the Releasees, you must exclude yourself (or “opt out”) from the Settlement Class. See Question 11 below for instructions on how to exclude yourself.

If you object to the Settlement, you must remain a Settlement Class Member (i.e., you may not also exclude yourself from the Settlement Class by opting out) and file a written objection in this case with the Court. (See Question 14 below.) If you object, you must still submit a Claim if you want a reimbursement.

If you do nothing, you may still receive the benefits of NHTSA Recall No. 24V-896, but you will get no reimbursement under the Settlement. Unless you exclude yourself, after the Settlement is granted final approval and the judgment becomes final, you will be bound by the judgment and you will never be able to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against the Releasees related to the claims released by the Settlement.

You may complete the Claim Form online at www.fcarecallreimbursement.com.

You must make a signed written request that (a) states your name, address, and phone number; (b) is signed by you or a person authorized by law to sign on your behalf; and (c) unequivocally states your desire to be excluded from the Settlement and Settlement Class. You must send your request by March 20, 2025, to this address:

Wilson, et al. v. FCA US LLC

c/o Kroll Settlement Administration LLC

P.O. Box 5324

New York, NY 10150-5324

No. If you exclude yourself, you may still receive the benefits of NHTSA Recall No. 24V-896, but you will not be entitled to any other Settlement benefits. However, you will also not be bound by any judgment in this Action.

No. Unless you exclude yourself, you give up any right to sue the Releasees for the claims that this Settlement resolves. You must exclude yourself from the Settlement Class to start your own lawsuit or to be part of any different lawsuit relating to the claims in this case. If you exclude yourself, do not submit a Claim requesting a reimbursement from this Settlement.

All Settlement Class Members who do not request exclusion from the Settlement Class have the right to object to the Settlement or any part of it. You can ask the Court to deny approval by filing an objection. You can’t ask the Court to order a different settlement; the Court can only approve or reject the Settlement. If the Court denies approval, no Settlement benefits will be sent out and the lawsuit will continue. 

Any objection to the proposed Settlement must be in writing, and it and any supporting papers must be filed with the Court and a copy mailed to Class Counsel and FCA US’s Counsel at the addresses listed below.
 

Objections must be filed or postmarked no later than March 20, 2025. 

To be considered by the Court, your objection must include: (i) the case name and number, i.e., Wilson, et al. v. FCA US LLC, No. 4:22-cv-00447 (E.D. Tex.); (ii) their full name, current address, and current telephone number; (iii) the model year and VIN of their Class Vehicle(s); (iv) a statement of the objection(s), including all factual and legal grounds for the position; (v) copies of any documents the objector wishes to submit in support; (vi) the name and address of the attorney(s), if any, who is representing the objecting Class Member in making the objection or who may be entitled to compensation in connection with the objection; (vii) a statement of whether the Class Member objecting intends to appear at the Final Approval Hearing, either with or without counsel; (viii) the identity of all counsel (if any) who will appear on behalf of the Class Member objecting at the Final Approval Hearing and all persons (if any) who will be called to testify in support of the objection; (ix) the signature of the Class Member objecting, in addition to the signature of any attorney representing the Class Member objecting in connection with the objection, and (x) the date of the objection.

In addition, any Class Member objecting to the Settlement shall provide a list of any other objections submitted by the objector, or the objector’s counsel, to any class action settlements submitted in any court in the United States in the previous five years. If the Class Member and their counsel has not made any such prior objection, the Class Member shall affirmatively so state in the written materials provided with the objection.

If you fail to object in this manner, you will be deemed to have waived and forfeited any and all rights you may have to appear separately and/or to object to the Settlement Agreement, and you shall be bound by all the terms of the Settlement Agreement and by all proceedings, orders, and judgments in the Litigation. The exclusive means for any challenge to the Settlement Agreement shall be through the provisions set forth in this paragraph. Without limiting the foregoing, any challenge to the Settlement Agreement, the Final Judgment and Order approving this Settlement Agreement, or the judgment to be entered upon final approval shall be pursuant to appeal under the Federal Rules of Appellate Procedure and not through a collateral attack.

The Court will hold a Fairness Hearing to decide whether to approve the Settlement. That Fairness Hearing is scheduled for April 11, 2025, at 9:00 A.M. C.T., at the Paul Brown United States Courthouse, 101 East Pecan Street, Sherman, Texas. At the Final Approval Hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate. If there are timely objections, the Court will consider them and will listen to people who have properly requested to speak at the Fairness Hearing. The Court may also consider Plaintiffs’ request for Attorneys’ Fees, Costs, and Expenses, and Plaintiffs’ request for Service Awards for Plaintiffs. After the Fairness Hearing, the Court will decide whether to approve the Settlement.

The Court could reschedule the Fairness Hearing to a different date or time without notice, so it is a good idea before the Fairness Hearing to check www.fcarambrakesettlement.com to confirm the schedule if you wish to attend.
 

No. You do not need to attend the Fairness Hearing unless you object to the Settlement and wish to appear in person. It is not necessary to appear in person to make an objection; the Court will consider any written objections properly submitted pursuant to the instructions in Question 14. You or your own lawyer are welcome to attend the Fairness Hearing at your expense, but you are not required to do so.
 

If the Court approves the Settlement, there may still be appeals. If an appeal is taken, it is possible the Settlement could be disapproved on appeal. We do not know how long this process may take.
 

If the Court does not approve the Settlement, there will be no Settlement benefits available to Settlement Class Members, Class Counsel, or Plaintiffs, and the case will proceed as if no Settlement had been attempted.
 

The Court has appointed the following Class Counsel to represent the Settlement Class in this Lawsuit:

Ben Barnow
Anthony L. Parkhill
Barnow and Associates, P.C.
205 W. Randolph Street, Suite 1630
Chicago, Illinois 60606

Bruce Steckler
Steckler Wayne & Love, PLLC
12720 Hillcrest Road
Dallas, Texas 75230

Stephen R. Basser
Barrack, Rodos & Bacine
600 West Broadway, Suite 900
San Diego, CA 92101

Settlement Class Members will not be charged for the services of Class Counsel; Class Counsel will be paid by FCA US, subject to Court approval. However, you may hire your own attorney at your own expense to advise you in this matter or represent you in making an objection or appearing at the Fairness Hearing. 

Plaintiffs will seek an order from the Court requesting that Attorneys’ Fees, Costs, and Expenses not to exceed $2,000,000.00 to Class Counsel. 

Plaintiffs will seek an order from the Court requesting that Service Awards in the amount of $3,000 be awarded to Representative Plaintiffs for their time and effort expended on behalf of the Settlement Class in the Action. 

You may contact the Settlement Administrator by mail or phone:

Mail:
Wilson, et al. v. FCA US LLC
c/o Kroll Settlement Administration LLC
P.O. Box 5324
New York, NY 10150-5324

Phone:
(833) 383-3648
 

PLEASE DO NOT CONTACT THE COURT OR FCA US’S COUNSEL FOR INFORMATION REGARDING THIS SETTLEMENT.