Brian Warner et al. v. Toyota Motor Sales, U.S.A., Inc., Class Action Settlement Frequently Asked Questions

If you do not find an answer to your question below, click here to contact us.

The settlement is now final and the frame inspection and replacement program relief to the Class is occurring, subject to the terms and conditions of the Settlement Agreement.



1. What vehicles are included in the settlement?


The following Toyota Tacoma, Tundra and Sequoia vehicles (called the “Subject Vehicles”) distributed for sale or lease in the United States, the District of Columbia, Puerto Rico and all other United States territories and/or possessions are included:



Model Years







Back to top

2. How do I know if I am part of the settlement?


You are part of the settlement if you are a person, entity or organization who, at any time as of or before December 2, 2016, own or owned, purchase(d), or lease(d) Subject Vehicles distributed for sale or lease in any of the fifty States, the District of Columbia, Puerto Rico or any of the territories or possessions of the United States.  This is called the “Class.”  

Excluded from the Class are: (a) Toyota, its officers, directors and employees; its affiliates and affiliates’ officers, directors and employees; its distributors and distributors’ officers, directors and employees; and Toyota Dealers and Toyota Dealers’ officers and directors; (b) Plaintiffs’ Counsel; (c) judicial officers and their immediate family members and associated court staff assigned to this case; and (d) persons or entities who or which timely and properly exclude themselves from the Class.

Back to top

3. What does the settlement provide?


If you are a Class Member, what you are eligible to receive depends on several factors.  The settlement benefits are outlined generally below, and more information can be found on this website.  

Please note that you may have to take action within certain deadlines to receive certain benefits.

Back to top

4. Frame Inspection and Replacement Program


For Class Members who still own or lease their Subject Vehicles, the Frame Inspection and Replacement Program is being implemented to determine whether a Class Member’s frame should be replaced in accordance with the terms of this settlement. The Frame Inspection and Replacement Program will begin following the date of Final Order and Final Judgment is entered and will be calculated by the longer of twelve (12) years from the date of the Subject Vehicle’s First Use, which is the date that the Subject Vehicle was originally sold or leased, or, if the Class Member has owned or leased the vehicle beyond twelve (12) years from date of First Use, one (1) year from the date of entry of the Final Order and Final Judgment. 

Pursuant to the Frame Inspection and Replacement Program and the Inspection Protocol, Toyota shall offer an initial inspection of the Subject Vehicles and additional inspections, as necessary.  Salvaged vehicles and vehicles with flood-damaged titles are not eligible for this benefit.  

Without cost to Class Members, upon request from the Class Member and if the Subject Vehicle is required by the Toyota Dealer to remain at the dealership at least overnight, Toyota will provide a Loaner Vehicle (upon proof of adequate insurance) for up to seven (7) days, absent exceptional circumstances, while the frame is being replaced.  The Frame Inspection and Replacement Program is transferable with the Subject Vehicle.  In appropriate circumstances where the Class Member has a demonstrated need for a vehicle similar to the Subject Vehicles, Toyota, through its dealers, shall use good faith efforts to satisfy that request.

If you are eligible for the Frame Inspection and Replacement Program, simply bring your Subject Vehicle to a Toyota Dealer for an inspection and, if required, a frame replacement. If you dispute the findings of the Toyota Dealer’s inspection, you may take your vehicle to a second Toyota Dealer for a second frame inspection.  

You also can obtain a document summarizing the Frame Inspection and Replacement Program on this website. You do not need to have the summary to receive the benefits of the Frame Inspection and Replacement Program, but it may serve as a reminder to you in the event your Subject Vehicle satisfies the Rust Perforation Standard.  

Toyota, at its discretion, may also periodically mail reminders of this benefit to Class Members after the issuance of the Final Order and Final Judgment.  The reminder notices will notify the Class Members of the timing of this Frame Inspection and Replacement Program and will encourage Class Members to bring in their Subject Vehicles for an inspection.  

Toyota will replace the frames and associated parts, as required, on the Subject Vehicles that satisfy the Rust Perforation Standard as stated in the Inspection Protocol that are presented to a Toyota Dealer during the Frame Inspection and Replacement Program. The frame replacement is at no cost to Class Members.  

Toyota dealerships shall inspect the frames of the Subject Vehicles presented to them to determine whether a frame should be replaced pursuant to the Settlement Agreement.  Class Members may have their Subject Vehicles’ frames inspected by authorized Toyota Dealers and, if the vehicle is located in a CRC State, for evaluation for application of the Corrosion Resistant Compounds (“CRC”).  Based upon the results of the inspection, and if perforation of the frame from rust corrosion meets or exceeds the Rust Perforation Standard, the Subject Vehicle’s frame and associated parts shall be replaced by Toyota at no charge to the Class Member.  If the perforation of the frame does not meet or exceed the Rust Perforation Standard, and the vehicle is currently registered in a CRC State, and the vehicle has not previously received CRC or a new frame, pursuant to a prior Limited Service Campaign (“LSC”), then the dealer or authorized sublet facility will apply CRC to the Subject Vehicle’s frame.  For vehicles registered in CRC States, the application of the CRC shall be available for a two (2) year period: (a) for the Tundra and Sequoia subject vehicles; and, (b) for those Tacoma subject vehicles for which CRC has not been previously applied and the frame was not previously replaced.  The timing of the availability of the CRC application will depend on Toyota’s ability to obtain the applicable environmental permits.  Toyota shall mail a reminder notice to Class Members in CRC States when there is only six (6) months remaining for the possible application of the CRC.

The CRC States include Connecticut, Delaware, the District of Columbia, Illinois, Indiana, Kentucky, Massachusetts, Maryland, Maine, Michigan, Minnesota, New Hampshire, New Jersey, New York, Ohio, Pennsylvania, Rhode Island, Virginia, Vermont, Wisconsin, and West Virginia.

All frames presented for inspection shall be inspected for perforations in the frame caused by rust corrosion in accordance with the following procedure: The frame will be inspected by a qualified Toyota technician, who will inspect the frame rails and cross member mounting locations.  Any perforation found will be measured to confirm if it is within the inspection criteria.   

If any perforation exists, but no perforation is 10 mm or greater and if the vehicle has not previously received CRC or a new frame, pursuant to the prior LSC, then the frame will be cleaned and the CRC will be applied for Subject Vehicles located in the CRC States.  If any perforation in the frame is found to be 10 mm or larger, then the frame will be replaced, as well as all applicable parts and service items incidental to frame replacement.

Back to top

5. Do I have a lawyer in the case?


Yes. The Court has appointed lawyers to represent you and other Class Members. These lawyers are called “Class Counsel”: Timothy Blood at Blood Hurst & O’Reardon, LLP and Ben Barnow at Barnow and Associates, P.C., are Class Counsel. Their contact information is as follows:

Timothy G. Blood
Blood Hurst & O’Reardon, LLP
701 B Street, Suite 1700
San Diego, CA 92101
Tel: (619) 338-1100
Fax: (619) 338-1101


Ben Barnow
Barnow and Associates, P.C.
1 North LaSalle Street, Suite 4600
Chicago, IL 60602
Tel: (312) 621-2000
Fax: (312) 641-5504

Back to top

6. How do I get more information?


The Notice you may have received summarizes the proposed settlement. More details are in the Settlement Agreement. You can get a copy of the Settlement Agreement and other information about the settlement in the important documents section of this website. You can also write the settlement administrator at Settlement Notice Administrator in Brian Warner et al. v. Toyota Motor Sales, U.S.A., Inc., (C.D. Cal.), c/o Heffler Claims Group, P.O. Box 910, Philadelphia, PA 19105-0910. You can also look at the documents filed in the lawsuit at the Court.

Back to top

This website is authorized by the Court, supervised by counsel and controlled by Heffler Claims Group, the Settlement Administrator approved by the Court. This is the only authorized website for this case.


Please read for a full explanation of the settlement and your options and all applicable timelines.


Contact us with any inquiries, comments, and/or requests.

Important Documents

Having Trouble?

Having trouble opening .pdf files? You can download Acrobat Reader  for free from

Copyright © 2019 Heffler Claims Group - All Rights Reserved. This site designed and developed by Heffler Claims Group - Privacy Policy