A manufacturer’s duty to honor a one-year warranty can be triggered by defects found beyond the warranty’s expiration date if the plaintiff can show that the problem was “manifest but undiscovered … due to the fault of the seller,” a federal judge has ruled.

And such a buyer can also bring fraud claims in addition to its contract claims if it can show that the “gist” of the fraud claim goes beyond the contract to focus on specific promises made outside the contract, the judge ruled.