Notes ·
Apple's Repair Restrictions Are Back in Court, and the Reason Matters
Joshua MorrisThe case is about Apple's repair practices from several years ago, but the reasoning behind the decision is much more interesting than that history.
Two iPhone owners sued Apple after paying the company to replace cracked screens in 2021.
They allege that Apple made independent repair artificially difficult through a combination of parts pairing, restricted access to parts and tools, warranty practices, proprietary hardware, and other barriers.
Apple successfully got the case dismissed.
Now California's Sixth District Court of Appeal has reversed that dismissal and allowed the central unfair competition claim to continue.
Apple has not been found liable.
The court is saying something much narrower at this stage:
The consumers have alleged enough of a case that they should be allowed to try to prove it.
But some of what the court says along the way is notable for right to repair.
You don't have to prove that another repair shop would have charged you less
This may be the most interesting part.
Apple argued, among other things, that the plaintiffs had not actually gone somewhere else for their repairs and shown that an independent shop would have charged less.
The court said that misses their argument.
Their theory is that Apple's restrictions suppressed competition throughout the repair market.
If that is true, then the injury isn't simply:
Apple charged me $280.
The shop down the street would have charged me $180.It can also be:
Apple's control over repair reduced competition,
so the $280 price itself was higher than it would
have been in a competitive repair market.That is a much bigger argument.
Parts pairing doesn't only affect the person trying to install a replacement screen themselves.
Withholding tools doesn't only affect the repair shop that cannot obtain them.
Restricting the supply of replacement parts doesn't only affect someone who wanted to buy one.
If those practices collectively reduce competition, everyone buying repair services can potentially pay more.
The court put it fairly plainly:
"Consumers needing out-of-warranty repairs have no means of avoiding marketwide pricing dynamics."
That is an important way to think about right to repair.
It isn't merely about whether I personally know how to replace an iPhone screen.
Competition from people who do know how can make my repair cheaper too.
Parts pairing is part of the case
The complaint describes Apple's use of parts pairing as one of the mechanisms that allegedly restricted independent repair.
Parts pairing associates components such as displays and batteries with a particular device.
Historically, replacing some paired components could result in warnings or loss of functionality unless Apple's software completed the repair process.
There can be legitimate security reasons for pairing certain components.
A stolen biometric sensor probably should not be something I can casually install into another phone and inherit trust from the original device.
But that does not mean every component needs the same treatment.
A screen is a screen.
A battery is a battery.
When software prevents an otherwise functional replacement component from working normally because the manufacturer did not authorize the repair, software has become part of the repair restriction.
That is one of the stranger developments in modern ownership.
We used to worry about whether we could physically open something.
Now you can open it, replace the broken part correctly, put everything back together, and still have software say:
No.
Wrong screwdriver, spiritually.
California's Right to Repair law matters even though it came later
There is another unusual part of the ruling.
The repairs in this lawsuit happened in 2021.
California's Right to Repair Act did not take effect until July 2024.
That means Apple could not have violated that law in 2021.
The appeals court explicitly acknowledges this.
But the judges still looked at the later law when considering whether the alleged practices were unfair under California's Unfair Competition Law.
California's Right to Repair Act establishes a public policy of providing a fair repair marketplace and prohibiting intentional barriers to third-party repair.
The court reasoned that the Legislature later establishing that right can help inform whether the earlier conduct alleged in this case was unfair.
That is fascinating.
The court isn't retroactively applying the Right to Repair Act.
Instead, it is effectively saying:
California has now clearly articulated the public policy involved here.
That policy can help us evaluate the alleged conduct under an older and broader unfair competition law.
There is a significant caveat.
This opinion has not been certified for publication, which means it generally cannot be cited as precedent in other California cases.
So this is not suddenly a new statewide rule allowing every old repair dispute to be reopened.
But the reasoning is still worth paying attention to.
The warranty argument is more complicated
There is also a useful distinction in the decision around warranties.
Federal law generally prevents manufacturers from saying something like:
Your warranty is void unless all repairs
are performed by us.A manufacturer can refuse to cover damage actually caused by an unauthorized repair.
That is different from voiding the warranty on the entire product simply because someone else worked on it.
The plaintiffs alleged that Apple employees told customers that obtaining outside repairs could cause Apple to refuse later warranty service.
The appeals court found those allegations relevant to the broader unfair competition claim.
But it did not revive the plaintiff's direct claim under the federal Magnuson-Moss Warranty Act.
Reading Apple's written warranty as a whole, the court concluded that it excludes damage caused by unauthorized service rather than automatically voiding all warranty coverage because someone else repaired the device.
That distinction matters.
This isn't a ruling that Apple's written warranty violated federal law.
It is a ruling allowing the broader alleged repair practices to be tested as unfair competition.
Apple has changed quite a bit since 2021
There is some historical awkwardness here too.
Apple launched Self Service Repair in 2022.
It later supported California's Right to Repair Act, which requires manufacturers to make documentation, parts, and tools available to owners and independent repair businesses on fair and reasonable terms.
Apple has also continued expanding repair options and changing how parts calibration works.
That is real progress.
This lawsuit is largely examining the Apple that existed before much of that happened.
But that doesn't make the case irrelevant.
If anything, it helps explain why right-to-repair laws became necessary.
Manufacturers discovered that software, proprietary parts, unavailable tools, restricted documentation, and warranty policies could give them enormous influence over products long after they sold them.
Legislatures eventually started pushing back.
Now courts are beginning to work through what those practices meant for consumers before the newer laws existed.
Repairability is part of competition
I have always thought right to repair gets framed too narrowly as a hobbyist issue.
It isn't just about people who want to take their phones apart.
I may never replace my own display.
I still benefit from someone else being allowed to.
Independent repair shops create competition.
Available parts create competition.
Published documentation creates competition.
Reusable components create competition.
Software that doesn't arbitrarily reject repaired hardware creates competition.
And competition puts pressure on everyone, including the manufacturer, to provide better repair service at reasonable prices.
That is the implication in this case I find most important.
The plaintiffs aren't simply arguing:
Apple wouldn't let us repair our phones.
They are arguing:
Apple's control over who could repair iPhones changed the economics of repair for everyone who owned one.
Now they will have an opportunity to try to prove it.
A cracked screen should not turn into a discussion about how much control the manufacturer still has over something you already bought.
You bought the phone.
Repair should be part of what ownership means.