Lemon Law Analysis

2023 Tesla Model 3

NHTSA Complaints · Active Recalls · California Lemon Law Data

✓ Reviewed by Jacob Shayesteh, Esq. · Updated June 2026
393
NHTSA Complaints
10
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 393 complaints against the 2023 Tesla Model 3. 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 Tesla Model 3 complaints directly on the NHTSA complaint database.

The 2023 Tesla Model 3 has generated 788 NHTSA complaints and has 10 active recalls. If your 2023 Tesla Model 3 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. Tesla pays all attorney fees when we prevail. You pay nothing.

Forward Collision System

High Claim VolumeSong-Beverly Strength: Very Strong

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 Tesla Model 3 has 146 NHTSA complaints for this defect type. Owner reports include: “In autopilot mode on 1/28/26 the vehicle without any warnings went through a red light causing an accident. A week prior it failed to adjust speed in a 35 mile per hour zone maintaining 71.” (NHTSA Complaint #11720413)

Steering

High Claim VolumeSong-Beverly Strength: Strong

Steering defects can create unpredictable vehicle behavior and qualify as safety-related under California lemon law. Reported issues on the 2023 Tesla Model 3 include pulling, vibration, loss of power steering, and electronic steering warnings. 98 NHTSA complaints have been filed in this category. Owner reports include: “The volume control buttons and vehicle setting buttons on my car’s steering wheel are made of metal. In high atmospheric temperatures the interior of the car heats up. The buttons also heat up and can cause burns if touching the button for an extended (more than 30 seconds) amount of time. This is very distracting while driving while also causing a mild burn.” (NHTSA Complaint #11659830)

Other Systems

High Claim VolumeSong-Beverly Strength: Moderate

The 2023 Tesla Model 3 has generated 54 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: “There is no manual door release for rear doors in the Tesla model 3 RWD. This can pose a safety issue if the car has no power and passengers need to evacuate the vehicle.” (NHTSA Complaint #11716471)

Vehicle Speed Control,Forward Collision Avoidance

High Claim VolumeSong-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 Tesla Model 3 has 40 NHTSA complaints for this defect type. Owner reports include: “My Tesla Model 3 disengaged cruise control while going 68 mph and braked hard for no apparent reason. I was driving northbound on I-405 at 3:45 a.m. going to LAX airport in the number 3 or 4 of six or seven lanes. Cruise control had been activated for at least 10 minutes before the incident at a speed of 68 mph. There was no traffic within half a mile before or after me due to the time of day. Neither my left or right foot were near either the brake or acceleration pedal, nor were they in motion. Both hands were on the steering wheel and no control was being activated. The only noticeable environmental condition is that the road surface had just changed from a dark gray asphalt to a bright white new concrete roadway. No emergency braking alert was seen or heard, so I do not think it was a false collision detection, and there was no car within a half mile. However, I do believe the severity of braking could have caused an accident if there had been someone behind me. Tesla Model 3 Software Version was v12 (2025.20.6 046c4575d120).” (NHTSA Complaint #11674647)

Electrical System

High Claim VolumeSong-Beverly Strength: Moderate

Electrical system failures are notoriously difficult to diagnose and repair, which often results in multiple unsuccessful repair attempts — a key element of a lemon law claim. Reported issues for the 2023 Tesla Model 3 include infotainment malfunctions, battery drain, warning lights, power window failures, and intermittent starting problems. 36 NHTSA complaints have been filed for this category. Owner reports include: “Door cannot be opened during power loss / emergency. I am a Tesla Model 3 owner in California. I discovered that the rear doors do not have a mechanical emergency release. Tesla service confirmed that my vehicle does not include any manual rear emergency door release system. This raises a serious safety concern because, in the event of a crash, fire, or 12V power failure, rear passengers—especially children or elderly occupants—may be unable to exit the vehicle. I request NHTSA to investigate whether the absence of a mechanical rear emergency release complies with FMVSS 206 and whether Tesla’s design poses a safety risk during emergency egress.” (NHTSA Complaint #11725482)

Active NHTSA Recalls — 2023 Tesla Model 3

The following 10 recalls have been issued for the 2023 Tesla Model 3 by the NHTSA or Tesla. If your vehicle is affected, the manufacturer is required to provide a free remedy. Check your VIN at NHTSA.gov/recalls.

Recall 22V844000

Component: EXTERIOR LIGHTING:TAIL LIGHTS

Defect: See NHTSA database for details.

Risk: A taillight that fails to illuminate may reduce the visibility of the vehicle, increasing the risk of a crash.

Remedy: Tesla has released an over-the-air (OTA) software update, free of charge. Owner notification letters were mailed January 14, 2023. Owners may contact Tesla customer service at 1-877-798-3752. Tesla’s number for this recall is SB-22-00-016.

Recall 21V834000

Component: AIR BAGS:SIDE/WINDOW:CURTAIN

Defect: See NHTSA database for details.

Risk: A twisted side curtain air bag may improperly deploy, increasing the risk of injury or occupant ejection during a crash.

Remedy: Tesla Service will inspect and realign the left and right side curtain air bag as necessary, free of charge. Owner notification letters were mailed December 23, 2021. Owners may contact Tesla customer service at 1-877-798-3752. Tesla’s number for this recall is SB-21-20-006.

Recall 23V085000

Component: STEERING:AUTOMATED/ADAPTIVE STEERING

Defect: See NHTSA database for details.

Risk: FSD Beta software that allows a vehicle to exceed speed limits or travel through intersections in an unlawful or unpredictable manner increases the risk of a crash.

Remedy: Tesla will release an over-the-air (OTA) software update, free of charge.  Owner notification letters were mailed April 15, 2023.  Owners may contact Tesla customer service at 1-877-798-3752.  Tesla’s number for this recall is SB-23-00-001.

Recall 23V434000

Component: ELECTRICAL SYSTEM:PROPULSION SYSTEM:TRACTION BATTERY

Defect: See NHTSA database for details.

Risk: A defective battery disconnect may not isolate the vehicle’s high voltage battery after a crash or fault detection, increasing the risk of electrical shock and injury.

Remedy: Tesla Service will replace the pyrotechnic battery disconnect, free of charge. Owner notification letters were mailed August 18, 2023. Owners may contact Tesla customer service at 1-877-798-3752. Tesla’s number for this recall is SB-23-16-005.

Recall 23V838000

Component: ELECTRICAL SYSTEM:ADAS:AUTONOMOUS/SELF DRIVING:SOFTWARE

Defect: See NHTSA database for details.

Risk: In certain circumstances when Autosteer is engaged, and the driver does not maintain responsibility for vehicle operation and is unprepared to intervene as necessary or fails to recognize when Autosteer is canceled or not engaged, there may be an increased risk of a crash.

Remedy: Tesla will release an over-the-air (OTA) software update, free of charge. Owner notification letters were mailed February 10, 2024. Owners may contact Tesla customer service at 1-877-798-3752. Tesla’s number for this recall is SB-23-00-008.

Recall 24V051000

Component: ELECTRICAL SYSTEM: INSTRUMENT CLUSTER/PANEL

Defect: See NHTSA database for details.

Risk: Warning lights with a smaller font size can make critical safety information on the instrument panel difficult to read, increasing the risk of a crash.

Remedy: Tesla began releasing an over-the-air (OTA) software update, free of charge. Owners may contact Tesla customer service at 1-877-798-3752. Tesla’s number for this recall is SB-24-00-003.

Recall 24V376000

Component: SEAT BELTS:FRONT:WARNING LIGHT/DEVICES

Defect: See NHTSA database for details.

Risk: A seat belt warning system that fails to alert occupants of an unbelted seat belt can increase the risk of injury during a crash.

Remedy: Tesla will release an over-the-air (OTA) software update. Owner notification letters were mailed July 26, 2024. Owners may contact Tesla customer service at 1-877-798-3752. Tesla’s number for this recall is SB-24-00-008.

Recall 24V554000

Component: LATCHES/LOCKS/LINKAGES:HOOD:LATCH

Defect: See NHTSA database for details.

Risk: An unlatched hood can fully open, obstructing the driver’s view and increasing the risk of a crash.

Remedy: Tesla has released an over-the-air (OTA) software update, free of charge. Owner notification letters were mailed September 24, 2024. Owners may contact Tesla customer service at 1-877-798-3752. Tesla’s number for this recall is SB-24-00-012.

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 Tesla Model 3:

  • 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 Tesla to prove the vehicle is not a lemon. Under Cal. Civ. Code § 1794(d), Tesla 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 Tesla Model 3 qualifies as a lemon under California law, Tesla 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), Tesla pays all legal fees if you prevail
  • Civil penalty up to 2x damages — If Tesla willfully violated the Act, courts may award double the actual damages

Steps to Protect Your 2023 Tesla Model 3 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 Tesla a reasonable opportunity to fix the defect. Visit different authorized Tesla 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), Tesla pays your fees if you win.

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

2023 Tesla Model 3 Lemon Law Questions

How many repair attempts qualify my 2023 Tesla Model 3 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 Tesla pay my attorney fees?

Yes. Under Cal. Civ. Code § 1794(d), Tesla 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 Tesla Model 3?

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 Model 3 Qualifies?

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

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