Buried in General Motors’ just-filed regulatory filing was one doozy of a disclosure: The automaker has already incurred $500 million in legal costs dealing with dozens of state attorneys general and class-action lawsuits over allegations that GM duped customers into allowing the company to track their driving habits — and then sold that data to insurance companies, which used it to raise premiums on drivers deemed more risky.
That eye-popping figure does not represent settlements or judgments. It represents the cost of processing, reviewing, and developing a comprehensive legal strategy to manage the litigation. Alarmingly, GM admits it cannot estimate the total cost of its potential liability.
On my LinkedIn page, a GM defender argued that $500 million is still “a drop in the bucket” for the automaker, which reported roughly $185 billion in 2025 revenue. If one wants to go down that road, $500 million happens to equal the total profit-sharing GM will pay its factory workers for 2025 — a 32 percent decline from the prior year, because earnings were impaired by CEO Mary Barra’s serial EV misadventures.
Calling $500 million a “drop in the bucket” is the executive-suite equivalent of telling the workers who build your cars: Let them eat cake.
In any case, GM’s litigation costs are plainly rising. And while Barra continues crowing to Wall Street that the company is firing on all cylinders, GM’s lawyers appear far less confident. They are repeatedly warning investors about gathering legal storm clouds.
From GM’s late-2024 regulatory filing, as reported by veteran auto writer Phoebe Wall Howard:
We are subject to legal proceedings in the U.S. and elsewhere involving various issues, including product liability lawsuits, warranty litigation, class action litigations alleging product defects, emissions litigation, privacy matters, stockholder litigation, labor and employment litigation and claims and actions arising from restructurings and divestitures of operations and assets. In addition, we are subject to various governmental proceedings and investigations. A negative outcome in one or more of these proceedings could result in the imposition of damages, including punitive damages, fines, reputational harm, civil lawsuits and criminal penalties, interruptions of business, modification of business practices, equitable remedies and other sanctions against us or our personnel as well as legal and other costs, all of which may be significant.
This is not boilerplate throat-clearing. This is a company effectively conceding that its legal exposure is sprawling, unpredictable, and potentially existential.
Frankly, while I’m not a lawyer, I suspect GM’s privacy violations may ultimately pale in comparison to what lies ahead in litigation relating to its 6.2-liter V8 engines.
GM has already recalled more than 720,000 vehicles from the 2021 through 2024 model years equipped with these supposedly “premium” engines because of the risk of catastrophic failure. Class action lawsuits are piling up, with allegations that GM knowingly sold vehicles with engines its own engineers understood were defective.
Worse, auto enthusiasts have posted numerous YouTube videos alleging that 2025 and 2026 vehicles equipped with the same 6.2L V8 engines are also failing prematurely — including reports of replacement engines failing as well.
Legendary GM executive Bob Lutz once said: “If the engine sounds cheap, feels cheap, or fails early, you’ve lost the customer forever.”
One wonders what Lutz would say about the loyalty of a customer whose engine failed — received a replacement — and then watched that engine fail too.
It seems hardly a reach to argue that GM may be morphing from an auto business with routine legal exposure into a legal enterprise attached to an auto business. Fortunately for GM’s shareholders, it would be hard to find an executive better suited to manage that reality than Grant Dixton, GM’s Executive Vice President, Chief Legal & Public Policy Officer.
Dixton, who joined GM in July 2024, is impeccably credentialed. A graduate of Harvard Law School, where he served on the Harvard Law Review, Dixton went on to clerk for the U.S. Court of Appeals and the U.S. Supreme Court. According to his official GM biography, Dixton later served “as associate counsel to the President of the United States, where he provided legal advice across a range of domestic policy areas, including environmental matters.”
GM notably neglected to name the president. It was George W. Bush.
Dixton’s Republican-era government ties are particularly useful for an automaker with deep regulatory exposure and expanding military ambitions. As Phoebe Wall Howard reported today, GM is now seeking a role in building NASA’s next-generation lunar rover.

But Dixton’s private-sector résumé may be even more instructive. Before arriving at GM, he held senior legal roles at Boeing and Activision — two companies that became case studies in how modern American corporations manage self-inflicted crises.
Like GM, both Boeing and Activision aggressively embraced stock buybacks, prioritizing financial engineering over long-term resilience. GM has authorized more than $50 billion in buybacks over the past decade. Boeing’s buyback binge, widely criticized in hindsight, hollowed out the company just as safety failures, regulatory scrutiny, and catastrophic product breakdowns mounted. Activision, meanwhile, used buybacks to boost share prices even as it faced years of allegations involving workplace misconduct and cultural rot.
These companies also shared another trait: executives insulated by legal strategy and rewarded lavishly despite mounting problems.
Boeing and Activision paid their CEOs outsized compensation packages while product quality, employee trust, and public credibility deteriorated. GM fits the pattern. CEO Mary Barra is paid roughly 80 percent more than the CEO of Toyota — the world’s largest automaker for six consecutive years — even as GM grapples with recalls, lawsuits, and a growing list of customer grievances.
Seen in that light, Dixton’s background is less a résumé coincidence than a logical progression. He has spent his career inside corporations that mastered the art of surviving the consequences of their own decisions — through buybacks, regulatory navigation, and aggressive legal containment. As GM’s litigation costs soar and its product failures multiply, that experience may now matter more than ever.
Fortunately for investors in Ford, which issued a record 152 safety recalls in 2025, the automaker’s general counsel and chief policy officer is as well credentialed as GM’s Dixton.
Steven Croley, whom I have previously profiled, earned his law degree from Yale, holds a doctorate in government from Princeton, served in senior legal roles in the Obama White House and at the Department of Energy, and made partner at the white-shoe law firm Latham & Watkins. He also served as associate dean at the University of Michigan Law School. Unlike GM, Ford explicitly identifies Barack Obama as the president under whom Croley previously served.

Class action firms that tangle with Croley do so at their own risk. In an audacious move, Ford last year retained the Kasowitz law firm to file a civil RICO complaint against a group of California lawyers and law firms, accusing them of violating the Racketeer Influenced and Corrupt Organizations Act through padded and inflated bills for allegedly unworked and phantom time. Ford claims those practices cost it, and other automakers, at least tens of millions of dollars.
Hot shot lawyers suing hot shot lawyers is corporate America’s version of social Darwinism.
Litigation is no longer an aberration in American business. It is a structural cost. Studies comparing overall liability costs, the dollars spent on claims whether resolved through lawsuits or other dispute mechanisms, show that the United States stands apart from other developed economies.
Measured as a percentage of GDP, U.S. liability have historically been roughly 2.6 times the average of surveyed Eurozone countries and about four times those of the least costly European jurisdictions. That gap reflects not only how often Americans sue, but how much money is at stake when they do.
GM and Ford are no longer world class at building cars. They are, however, very sophisticated at managing the litigation that flows from that decline, a skill that now appears more central to their business than engineering prowess. Their long-term survival may ultimately rest with their lawyers.