Lemon Law Analysis

2023 Subaru Forester

NHTSA Complaints · Active Recalls · California Lemon Law Data

✓ Reviewed by Jacob Shayesteh, Esq. · Updated June 2026
63
NHTSA Complaints
1
Active Recalls
2-4
Avg. Repair Attempts

The NHTSA tracks consumer complaints, manufacturer recalls, and safety investigations for every vehicle sold in the United States. These publicly available records are a critical resource for California lemon law cases because they establish patterns of recurring defects.

As of June 2026, the NHTSA has logged 63 complaints against the 2023 Subaru Forester. Each complaint is filed by a vehicle owner or lessee through the NHTSA’s Vehicle Safety Hotline or online portal at SaferCar.gov. You can review all 2023 Subaru Forester complaints directly on the NHTSA complaint database.

The 2023 Subaru Forester has generated 63 NHTSA complaints and has 1 active recall. If your 2023 Subaru Forester has experienced a defect that the dealer has been unable to repair after multiple visits, you may qualify for a full repurchase or replacement under California lemon law. Subaru pays all attorney fees when we prevail. You pay nothing.

Visibility/Wiper

Moderate Claim VolumeSong-Beverly Strength: Very Strong

The 2023 Subaru Forester has generated 10 NHTSA complaints for this defect category. If your vehicle has experienced recurring issues in this area that the dealer has been unable to repair after multiple attempts, you may have a qualifying lemon law claim under California’s Song-Beverly Consumer Warranty Act. Owner reports include: “Windshield developed a crack during a week with wild temperature swings. There was no incident leading up to the development of the crack that would have caused an initial chip or point of failure. The initial crack appeared during the day where the temperature went from the mid-60s to below freezing with precipitation in a matter of hours. Crack was not present in warm AM and appeared during cold PM. It grew (initial crack ended where the scotch tape is) during a day later that week with another wild temperature swings. Clearly a failure in the tempering process and insufficient QA for the component.” (NHTSA Complaint #11649212)

Other Systems

Moderate Claim VolumeSong-Beverly Strength: Strong

The 2023 Subaru Forester has generated 9 NHTSA complaints for this defect category. If your vehicle has experienced recurring issues in this area that the dealer has been unable to repair after multiple attempts, you may have a qualifying lemon law claim under California’s Song-Beverly Consumer Warranty Act. Owner reports include: “This complaint is in relation to a 2023 Subaru Forester. The car was purchased new at White River Subaru in White River Junction, VT less than two years ago. Before it reached 30,000 miles the following problem has arisen 1) rusty brakes and pads 2) a wheel bearing had to be replaced 3) a faulty tire pressure gauge. However, must concerning, I noticed greasy film was forming on the inside of the windshield. I took it dealership and was told there was an AC leak in the engine bay. The service shop told me the substance on the windshield was condensation. I do not believe this to be true. The substance created a visible film across the glass, when it did met with condensation and cold it turned a solid milky color with almost no visibility through the windsheild. When touched the film smudgles and has a greasy texture. I am concerned as this has serious health implications.” (NHTSA Complaint #11686174)

Forward Collision System

Emerging PatternSong-Beverly Strength: Moderate

Advanced driver assistance system (ADAS) defects — including malfunctioning forward collision warnings, lane keep assist failures, and erratic automatic emergency braking — can create dangerous driving conditions. The 2023 Subaru Forester has 4 NHTSA complaints for this defect type. Owner reports include: “In driving our 2023 Subaru Forester at 45mph at 10:00 am in the morning, with NO cars in front of us, in back of us, or on either side of us- suddenly the brakes locked up! Had there been anyone behind us, there could have been a dangerous collision. We have owned this car for 2 years, done all maintenance on it, and have NEVER had this happen before. We feel unsafe driving it now. We pulled the car over, got out to look under the car, thinking maybe we hit something in the road…but there was nothing…no warning….we contacted Subaru corporate, was given a Case number, but are still waiting to hear from them.” (NHTSA Complaint #11670232)

Air Bags

Emerging PatternSong-Beverly Strength: Moderate

Airbag defects are safety-critical and may trigger California’s two-repair threshold under Cal. Civ. Code § 1793.22. The 2023 Subaru Forester has 3 NHTSA complaints on record related to airbag warning lights, unexpected deployment, and sensor failures. Owner reports include: “1. The passenger seat air bag turn on mechanism malfunctions in a 2023 Subaru Forester Limited. The seat mechanism can be tested (and has been tested) upon request. 2. An adult that weighs 104lbs is not detected when in the seat, so the air bag is not turned on. 3. The problem has been reproduced by two dealers. 4. No other parties have inspected the car seats or the mechanism. 5. The problem indicator is the status light that shows the air bag as off or on. 6. Testing of the car by the dealer found no problems with the setup of the SRS and seat detection technology. Employees weighing more than the customer getting into the seat turned on the air bag. 7. Testing with the customer reproduced the problem 100% of the time. Testing was done by having the adult get into the seat multiple times after a restart of the vehicle. The air bag light never turned on. 8. The same test was performed with the adult customer using a different Forester. The detection mechanism of the other Forester also failed to detect the customer 100% of the time.” (NHTSA Complaint #11722519)

Exterior Lighting

Emerging PatternSong-Beverly Strength: Moderate

The 2023 Subaru Forester has generated 3 NHTSA complaints for this defect category. If your vehicle has experienced recurring issues in this area that the dealer has been unable to repair after multiple attempts, you may have a qualifying lemon law claim under California’s Song-Beverly Consumer Warranty Act. Owner reports include: “Factory installed headlights are dangerous as the low beam has a black line approximately halfway in the field of vision. Subaru states this is to keep from blinding oncoming vehicles. Driving in town not too bad, however in rural mountain areas with winding roads the headlights do not provide necessary lighting causing driving to be extremely dangerous. Low beams should not blind oncoming traffic. Dealer states these “projection” headlights cannot be replaced with traditional headlights. Complaint filed with Subaru who inform they can’t take any action; however state in voice mail that “although not recommended” after market headlights could be installed when available. Dealer has previously informed that installation of standard headlights may void warranty. Mechanics consulted recommend driving with high beams, oncoming traffic will see why when low beams activated. Another recommendation has been to always drive with fog lights on and possibly install LED lamps in fog lights, to add additional brightness. This type of headlights should be investigated to prevent unnecessary accidents. (Another horrible idea with the Subaru headlights is that they “Swing” as the car goes around curves, this feature can be turned off though.)” (NHTSA Complaint #11641177)

Active NHTSA Recalls — 2023 Subaru Forester

The following 1 recall has been issued for the 2023 Subaru Forester by the NHTSA or Subaru. If your vehicle is affected, the manufacturer is required to provide a free remedy. Check your VIN at NHTSA.gov/recalls.

Recall 23V754000

Component: POWER TRAIN:DRIVELINE:DRIVESHAFT

Defect: See NHTSA database for details.

Risk: A broken driveshaft can cause a loss of drive power while driving or vehicle rollaway when the vehicle is in park without the parking brake engaged. Either of these scenarios can increase the risk of a crash.

Remedy: Dealers will inspect and replace the left and right front driveshafts as necessary, free of charge. Owner notification letters were mailed January 8, 2024. Owners may contact Subaru’s customer service at 1-844-373-6614. Subaru’s number for this recall is WRP-23.

California Lemon Law — Song-Beverly Act

California’s Song-Beverly Consumer Warranty Act (Cal. Civ. Code §§ 1790–1795.8) is one of the strongest lemon laws in the United States. It protects buyers and lessees of new and certified pre-owned vehicles that develop substantial defects the manufacturer cannot repair after a reasonable number of attempts.

Under Cal. Civ. Code § 1793.22, a lemon law presumption is triggered when any of the following apply to your 2023 Subaru Forester:

  • 4+ repair attempts for the same non-safety defect without resolution
  • 2+ repair attempts for a defect likely to cause death or serious bodily injury
  • 30+ calendar days out of service for warranty repairs (cumulative, not consecutive)

Once the presumption is triggered, the burden shifts to Subaru to prove the vehicle is not a lemon. Under Cal. Civ. Code § 1794(d), Subaru must pay your attorney’s fees if you prevail — meaning qualified representation costs you nothing out of pocket.

What You Can Recover

If your 2023 Subaru Forester qualifies as a lemon under California law, Subaru may be legally required to:

  • Repurchase your vehicle — Full refund of your down payment, all monthly payments, registration fees, and incidental costs (towing, rentals), minus a mileage offset for miles driven before the first repair attempt
  • Replace your vehicle — Provide a new, comparable vehicle at no cost to you
  • Pay your attorney’s fees — Under § 1794(d), Subaru pays all legal fees if you prevail
  • Civil penalty up to 2x damages — If Subaru willfully violated the Act, courts may award double the actual damages

Steps to Protect Your 2023 Subaru Forester Claim

Step 1: Document every repair visit. Keep all repair orders, work orders, and dealer invoices. Each visit counts as a repair attempt, even if the dealer says nothing is wrong.

Step 2: Keep returning for repairs. You must give Subaru a reasonable opportunity to fix the defect. Visit different authorized Subaru dealers if needed and ask for written documentation of each visit.

Step 3: Contact a California lemon law attorney. Once you believe the threshold has been met — 4 attempts for non-safety defects, 2 for safety defects, or 30 days out of service — contact an attorney for a free case evaluation. Under § 1794(d), Subaru pays your fees if you win.

Step 4: Send a demand letter. Your attorney will send Subaru a formal demand letter. Most California lemon law cases resolve through negotiation without going to trial.

2023 Subaru Forester Lemon Law Questions

How many repair attempts qualify my 2023 Subaru Forester as a lemon?

Under Cal. Civ. Code § 1793.22, four or more repair attempts for the same non-safety defect, or two attempts for a safety-related defect, triggers the lemon law presumption. Additionally, 30 or more cumulative days out of service qualifies regardless of the number of repair attempts.

Does Subaru pay my attorney fees?

Yes. Under Cal. Civ. Code § 1794(d), Subaru is required to pay your reasonable attorney’s fees and court costs if you prevail in a lemon law claim. This means qualified lemon law representation is free to you if your case succeeds.

Can I file a lemon law claim without an active recall?

Yes. A recall is not required to file a lemon law claim. The Song-Beverly Act covers any substantial defect that impairs the use, value, or safety of the vehicle that the manufacturer cannot repair after a reasonable number of attempts. NHTSA complaints support the claim by establishing a pattern, but are not a prerequisite.

What is the time limit to file a lemon law claim for my 2023 Subaru Forester?

California lemon law claims are generally subject to a four-year statute of limitations from the date you discovered or should have discovered the defect. However, you must still be within the manufacturer’s original warranty period when the defect first appears. Contact an attorney promptly to preserve your rights.

Think Your 2023 Forester Qualifies?

Get a free case evaluation. Subaru pays our fees if you win — you pay nothing upfront.

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