Gonzales v. CarMax Auto Superstores LLC, No. 14-56842 (9th Cir. 2016)
Annotate this CasePlaintiff filed suit against CarMax, alleging violations of four California consumer protection laws: (1) the Consumer Legal Remedies Act (CLRA); (2) the Song-Beverly Consumer Warranty Act (Song-Beverly); (3) common law fraud and deceit; and (4) the Unfair Competition Law (UCL). Plaintiff's claims under the CLRA and UCL were both based on CarMax’s alleged violation of California Vehicle Code section 11713.18(a)(6), which requires a car dealer to provide consumers with a “completed inspection report” prior to the sale of any “certified” vehicle. The district court dismissed the fraud and Song-Beverly claims and granted CarMax summary judgment on his CLRA and UCL claims. The court concluded that the district court did not err in exercising diversity-based subject matter jurisdiction over his case. The court concluded that when the potential cost of complying with injunctive relief is considered along with plaintiff's claims for compensatory damages and punitive damages, the district court did not err in finding that the jurisdictional amount-in-controversy requirement was satisfied. The court held that a report, like the ones in this case, that fails to indicate the results of an inspection in a manner that conveys the condition of individual car components to a buyer is not a "completed inspection report" under California law. The court noted that if CarMax’s generic, and ultimately uninformative, list of components inspected were considered a “completed inspection report,” section 11713.18(a)(6)’s effectiveness in promoting transparency in the sale of certified cars would be substantially diminished. Therefore, the court reversed and remanded the district court's grant of summary judgment to CarMax on the CLRA and UCL claims.
Court Description: California Law. The panel reversed the district court’s summary judgment in favor of CarMax Auto Superstores, LLC, and remanded with instructions to enter summary judgment for Travis Gonzales on his Consumer Legal Remedies Act and Unfair Competition Law claims, based on CarMax’s alleged violations of California Vehicle Code section 11713.18(a)(6), which requires a car dealer to provide consumers with a “completed inspection report” prior to the sale of any “certified” used vehicle. The panel held that the district court properly exercised diversity-based subject matter jurisdiction over the case. The panel held that the district court did not err in finding that the jurisdictional amount-in-controversy requirement was satisfied where the potential cost of complying with injunctive relief was considered along with Gonzales’s claims for compensatory damages and punitive damages. Interpreting the requirements of Cal. Veh. Code § 11713.18(a)(6), the panel held that a report that fails to indicate the results of an inspection in a manner that conveys the condition of individual car components to a buyer is not a “completed inspection report” under California law. The panel concluded that CarMax’s generic list of car parts inspected failed to inform consumers of the material results of the inspection. 4 GONZALES V. CARMAX
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.