Brooks v. CarMax Auto Superstores
Annotate this CaseDefendant CarMax Auto Superstores California LLC (CarMax) advertised and sold cars as "certified" used vehicles. It sold a 2008 used Jeep Wrangler to plaintiff Jessica Brooks. CarMax had promoted the Jeep as a certified used vehicle, inspected the Jeep, made some repairs, and ultimately placed a signed "Certified Quality Inspection" document (the CQI Certificate) for the Jeep in the Jeep's glove box. The CQI Certificate remained in the glove box at all relevant times. Several months after Brooks purchased the Jeep, she drove it through a deep puddle and the engine was so severely damaged that it had to be replaced. She thereafter demanded (among other things) that CarMax rescind the purchase agreement and buy the Jeep back. When CarMax rejected her demands, she filed this action alleging it violated Vehicle Code section 11713.18, because neither the content of the CQI Certificate nor its method of delivery to her complied with CarMax's duties under section 11713.18. Brooks pleaded claims against CarMax under California's Consumer's Legal Remedies Act and Unfair Competition Law. The trial court ruled Brooks had suffered no damage from CarMax's alleged violations of section 11713.18, and therefore concluded she did not have standing to pursue claims under the CLRA or the UCL. Brooks argued on appeal to the Court of Appeal that reversal was warranted because she adequately demonstrated the type of damage necessary to prosecute a claim under the CLRA or the UCL or, alternatively, she was entitled to prosecute her claims under the CLRA or the UCL without showing any injury. Finding no reversible error, the Court of Appeal affirmed the trial court.
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