and methodologies have been treated differently by the same manufacturer under variable internal guidelines. Each case study highlights the lack of evaluation consistency, transparent standards and uniform enforcement of manufacturer policies across all dealer submissions. Case Study 1: Same Store Parts & Labor Submissions with Different Rules A dealer submitted requests for warranty parts and labor rate increases during mid-2025. The requests were submitted to their manufacturer in quick succession — both within a one-month period. After reviewing the labor request (which was submitted for review first), the manufacturer approved the dealer for a slightly reduced warranty labor rate, having made several adjustments inconsistent with rules and policies upheld in years prior. Just two days later, the dealer filed a parts request using nearly the same set of repair orders; 89 out of 90 days used in each request overlapped, with a variance of only a single day. Each submission was prepared under identical rules, with parts adjusted based on the manufacturer’s RO-by-RO feedback provided in response to the dealer’s labor request. Despite the nearly identical range, the manufacturer cited and adjusted the handling of 19 entirely different repairs that were not cited in the manufacturer’s review of the previously approved labor sample. In other words, the manufacturer’s rules regarding what constitutes a “qualifying repair” had changed within just a 48-hour period. The dealer, therefore, requested that the parts markup be approved using the same methodology and logic that governed the labor approval, proposing an amended markup aligned with the original figure requested, rather than the three-point reduction resulting from this disparate treatment. When submissions are prepared utilizing the same methodology, manufacturers should ensure parity across evaluations. Divergence in review criteria between labor and parts requests undermines procedural fairness and erodes dealer confidence in manufacturer processes. Case Study 2: Statutory Interpretation and Shifting Rules In another case, a dealer challenged a manufacturer’s inconsistent interpretation of a state warranty statute, year over year, with no relevant change to the state statute in reference. In early 2025, the manufacturer in question cited the absence of “warranty-like” language in the applicable state statute, asserting that repairs completed due to damage/ outside influence (rodent damage, accident damage and other factors that would never be covered under a manufacturer’s warranty) should be included in the calculation. This interpretation was completely off base, considering the fact that the entire intent of the statutory language is to include work that would be covered under a manufacturer’s warranty and to exclude work that is not. The manufacturer’s very own behavior contradicted their previously stated stance. In 2023, the manufacturer took the exact opposite stance to reduce the exact same dealer’s request, having stated that repairs completed due to “outside influence” should be removed from the calculation, only to reverse that position in 2025 when doing so worked to the manufacturer’s advantage. In both cases, the stance taken resulted in a reduced submitted rate; excluding such repairs reduced the dealer’s approved rate in 2023, while including this category reduced the approved rate in 2025. Having taken notice of this contradiction, the dealer asserted a claim of disparate treatment, arguing that the manufacturer’s inconsistent rule application constituted an unfair practice. However, the manufacturer was unwilling to amend its stance, ultimately stating that its handling of the request in 2025 was aligned with the state statute’s guidelines, offering no further insight into why the dealer’s requests were handled differently year over year, in accordance with the same statutory guidelines. When manufacturers alter interpretive positions without a transparent rationale, they invite credible claims of disparate treatment. Even if statutory language supports flexibility, manufacturers should maintain internal consistency to preserve fairness and trust. Case Study 3: Year-Over-Year and Store-To-Store Inconsistency Between 2020 and 2023, this dealer completed retail warranty submissions successfully under state law without issue, achieving full approvals for each request. Over the course of this time frame, the manufacturer in question consistently excluded certain repair categories as maintenance and/or “not warranty-like,” including brakes, wiper blades, keys, wheel locks and carbon cleaning, to name a few, from retail warranty calculations. In 2024, however, with no change to the language in the state statute, the manufacturer erroneously included these categories for the first time without explanation, significantly lowering the dealer’s requested rate. When the dealer challenged the inconsistency, citing past handling of their requests and 12 California New Car Dealer Quarterly
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