If you own a Wrangler 4xe or Grand Cherokee 4xe, you may have received a letter telling you to park outside, away from buildings, and to stop charging the plug-in battery until a repair is available. Some owners have been through more than one of these recalls; others have had the vehicle shut down on the road. If that is your Jeep, the Jeep 4xe lemon law question is a fair one: California's Song-Beverly Consumer Warranty Act can require the manufacturer to repurchase or replace a vehicle it cannot fix within a reasonable number of attempts.
This guide lists the documented 4xe recalls with NHTSA campaign numbers, explains how recall visits, lost days and safety defects fit a lemon law claim, and lists what to keep. It is general information about California law as of October 2026, not legal advice, and it does not suggest that every 4xe is defective.
The 4xe high-voltage battery fire recalls
The Wrangler 4xe and Grand Cherokee 4xe are plug-in hybrids with a high-voltage traction battery. FCA US (Stellantis) has recalled that battery three times for fire risk, and each later recall told owners whose vehicles had the earlier repair to come back for the new one.
| NHTSA campaign | Filed | Vehicles | What NHTSA's record says |
|---|---|---|---|
| 23V-787 | November 2023 | 2021–2023 Wrangler 4xe (32,125 vehicles) | High-voltage battery may fail internally and cause a fire while parked or driving. Park outside, away from structures, and do not recharge until repaired. Later superseded by 24V-720. |
| 24V-720 | September 2024 | 2020–2024 Wrangler 4xe and 2022–2024 Grand Cherokee 4xe (154,032 vehicles) | Same fire risk. Remedy: battery software update and battery pack replacement if needed. Vehicles repaired under 23V-787 need this remedy too. Later superseded by 25V-741. |
| 25V-741 | October 2025 | 2020–2025 Wrangler 4xe and 2022–2026 Grand Cherokee 4xe (320,068 vehicles) | Same fire risk. Owners told to park outside and not charge until the remedy is done. Dealers update the battery software and replace the battery as needed. Vehicles repaired under 24V-720 and 23V-787 need this remedy. |
When the 25V-741 recall was filed, Design News reported that Stellantis was aware of 19 fires originating from the battery pack, nine of them in vehicles that had already received the earlier recall remedy, and that the hazard was traced to battery separator material from the cell supplier, Samsung SDI. The same report said no permanent fix had been announced at that time. Check your VIN at nhtsa.gov/recalls for current remedy status.
Other 4xe recalls: power loss and fire
The battery is not the only 4xe recall. These involve loss of drive power or fire risk, which matters because the lemon law treats safety defects differently.
- 22V-865 (2021–2023 Wrangler 4xe, 62,909 vehicles): a communication loss can shut down the 2.0L engine and cause loss of drive power. The remedy is a software update so a fault puts the vehicle in limp-home mode instead of shutting down.
- 25V-576 (2022–2026 Grand Cherokee plug-in hybrid, 91,787 vehicles): a software error in the hybrid control processor may cause loss of drive power. The remedy is a software update.
- 26V-363 (2021–2025 Wrangler, including Wrangler 4xe, and Gladiator): wiring for the electric power steering pump may overheat and cause a fire, even when the vehicle is parked and off. Owners are told to park outside until repaired.
Recall lists change. Our recall and complaint lookup tool pulls the current NHTSA data for your model and year.
Does a recall make my 4xe a lemon?
Not by itself. A recall shows a safety defect in a group of vehicles. A lemon law claim is about your vehicle: a warranty defect that substantially impairs its use, value or safety, and a manufacturer that had a reasonable chance to fix it and did not.
Recalls still matter for 4xe owners in three ways.
- A recall visit can be a repair attempt. When the dealer performs a recall remedy for the same problem you are dealing with, that visit is a chance the manufacturer had to fix it. If the problem comes back, or the remedy is later declared inadequate and replaced by a new recall, the history counts in your favor.
- The recall record describes the risk in the manufacturer's own words. The NHTSA records for these campaigns say a battery fire or loss of drive power "can increase the risk of injury" or of a crash. That language helps show a defect is a safety defect.
- An unremedied recall is not a repaired vehicle. A 4xe you are told not to charge, and to keep away from your garage, is not delivering what you paid for.
How the lemon law applies to the 4xe
Civil Code § 1793.2(d) requires a manufacturer that cannot conform a new vehicle to its express warranty after a reasonable number of attempts to replace it or make restitution, and the buyer chooses which. California also gives buyers a presumption, often called the Tanner Act, in Civil Code § 1793.22(b). Within the first 18 months after delivery or 18,000 miles, whichever comes first, the law presumes a reasonable number of attempts if:
- the same defect is likely to cause death or serious bodily injury if the vehicle is driven, it has been subject to repair two or more times, and you directly notified the manufacturer at least once; or
- the same defect has been subject to repair four or more times, and you directly notified the manufacturer at least once; or
- the vehicle has been out of service for repair of defects for more than 30 calendar days in total since delivery.
The direct-notice requirement applies only if the manufacturer clearly disclosed it in the warranty or owner's manual, and the notice goes to the address the manufacturer gives there. Check your 4xe warranty booklet. If the manufacturer runs a qualified third-party dispute program and told you about it in writing, you may have to use that program before relying on the presumption (§ 1793.22(c)).
The presumption is a shortcut, not the only path. A claim can still succeed after 18 months when the record shows the defect was not fixed in a reasonable number of attempts. Our guide on how many repair attempts the lemon law requires explains this in more detail.
Battery fire and power loss as safety defects
Under the presumption, a defect "likely to cause death or serious bodily injury" needs only two repair attempts, not four. A battery that may catch fire while parked or driving, or a powertrain that may shut down on the road, are strong candidates for that category. Whether a particular defect qualifies is a question of fact.
Days you could not use the vehicle
The 30-day rule counts days out of service for repair, added up across visits, including days waiting at the dealer for a battery or parts. Civil Code § 1793.2(b) separately requires warranty repairs to be completed within 30 days unless you agree otherwise in writing, with extra time only for delays beyond the manufacturer's control.
Days when you kept the vehicle but were told not to charge it are harder; whether they count is a legal question that depends on the facts. Record them anyway, with any loaner or rental you did or did not get. They show the impairment of use either way.
A note on the class action
Owners have also sued as a class. CarComplaints reported in January 2025 that a proposed class action, Frisch v. FCA US LLC, was filed in federal court in the Eastern District of Michigan over 2020–2024 Wrangler 4xe and 2022–2024 Grand Cherokee 4xe vehicles. The complaint alleges that the battery recalls did not fix the fire risk and that FCA should have warned buyers. These are allegations, and we have not found a reported ruling or settlement as of October 2026.
A class case seeks relief for a large group. A lemon law claim is your own, based on your own repair history, and it can lead to a full repurchase. If you receive a class settlement notice, have a lawyer review it before you act, because opting in or out can affect your individual claim.
What to keep for a Jeep 4xe claim
- Every repair order, including recall visits. Each should show your complaint, the recall or diagnostic code, what was done and the dates in and out.
- Every recall letter, including the interim "park outside, do not charge" notice and any later letter saying the remedy is ready.
- Photos of dashboard warnings, app alerts, and tow records if the vehicle lost power.
- A log of days in the shop, days you could not charge, and extra fuel or rental costs.
- Your case number with Stellantis. The NHTSA recall records list Chrysler customer service at 800-853-1403. Write down the date, the person and what you were told each time.
What to do next
- Follow the safety instructions in the recall notice, and get the remedy done when it is available.
- If the problem comes back or the vehicle loses power again, take it in right away and make sure the repair order describes it.
- Do not sign a trade-in deal, goodwill payment or release from the dealer or Stellantis without having it reviewed.
- Do not send a lemon law demand letter on your own. Stellantis (FCA) has been reported among the manufacturers that opted in to California's 2025 lemon law procedures, which require a specific pre-suit notice before you can seek civil penalties.
What you can recover and the deadlines
A repurchase generally covers what you paid or owe, including taxes, registration and finance charges, plus incidental costs such as towing and rentals, minus a mileage offset for miles driven before you first took the vehicle in for the defect (Civil Code § 1793.2(d)(2)). Our lemon law buyback calculator runs the numbers. If the manufacturer willfully failed to comply, a court can add a civil penalty of up to two times actual damages, and a buyer who wins recovers attorney's fees and costs (Civil Code § 1794).
For manufacturers that opted in to the 2025 procedures, a lawsuit generally must be filed within one year after the warranty expires and no later than six years after delivery. Confirm current status on the Department of Consumer Affairs list, and read our guide to the 2025 lemon law changes under AB 1755. For other Chrysler, Dodge, Jeep and Ram questions, see our Jeep, Chrysler, Dodge and Ram lemon law guide, and for plug-in charging issues more broadly, our guide to EV battery and charging problems.
How LaCour handles Jeep 4xe claims
LaCour Trial Lawyers handles California lemon law claims statewide, in English and Spanish, with trial counsel leading each case. When a claim succeeds, the law requires the manufacturer to pay the buyer's attorney's fees and costs. Send us your recall letters and repair orders for a free, confidential review.
Frequently asked questions
Is my Jeep 4xe a lemon because of the battery fire recall?
Not automatically. But repeat recall repairs, a fix that does not work, power loss, or long stretches when you cannot safely use or charge the vehicle can support a claim. It depends on your repair history.
How many repair attempts does a 4xe need to qualify?
In the first 18 months or 18,000 miles, the law presumes a lemon after two attempts for a defect likely to cause death or serious injury, four attempts for the same defect, or more than 30 days in the shop. Claims can also succeed outside those numbers.
Do days I was told not to charge my 4xe count toward the 30 days?
The 30-day rule counts days out of service for repair, so days at the dealer count. Days at home under a do-not-charge notice are a harder question that depends on the facts. Keep a log either way.
Does the Grand Cherokee 4xe have the same battery recall as the Wrangler 4xe?
Yes. NHTSA recalls 24V-720 and 25V-741 cover both the Wrangler 4xe and the Grand Cherokee 4xe for high-voltage battery fire risk. The Grand Cherokee plug-in hybrid also has a separate loss-of-drive-power recall, 25V-576.
Should I join the Jeep 4xe class action instead of filing a lemon law claim?
They are different. A lemon law claim is your own and can lead to a full repurchase. Talk to a lawyer before opting in or out of any class settlement.
What does a 4xe lemon law buyback include?
Generally the price paid, taxes, registration, finance charges and incidental costs, minus a mileage offset for miles driven before the first repair visit for the defect. You can choose a replacement instead.
Sources
- NHTSA, Recall 23V-787, Wrangler PHEV high-voltage battery, November 2023
- NHTSA, Recall 24V-720, Wrangler 4xe and Grand Cherokee 4xe high-voltage battery, September 2024
- NHTSA, Recall 25V-741, Wrangler 4xe and Grand Cherokee 4xe high-voltage battery, October 2025
- NHTSA, Recall 22V-865, Wrangler 4xe engine shutdown, November 2022
- NHTSA, Recall 25V-576, Grand Cherokee PHEV loss of drive power, September 2025
- NHTSA, Recall 26V-363, Wrangler and Gladiator power steering pump wiring, June 2026
- Design News, "Stellantis Recalls 320,000 Jeep Plug-In Hybrids Due To Fire Risk & Failed Previous Fix," November 2025
- CarComplaints, Jeep 4xe battery recall lawsuit (Frisch v. FCA US LLC), January 2025
- California Civil Code § 1793.22 (Tanner Act presumption)
- California Civil Code § 1793.2 (repair, repurchase and offset)
- Norman Taylor & Associates, "Which Car Manufacturers Opted Into California's New Lemon Law?," November 2025
- California Department of Consumer Affairs, Arbitration Certification Program, manufacturers list
This guide is general information about California and federal law and about public records as of its date. It is not legal advice, and reading it or contacting us does not create an attorney–client relationship. Allegations in lawsuits are claims, not findings. Prior results do not guarantee a similar outcome. Attorney advertising.