Garcia v. Medved Chevrolet, IncAnnotate this Case
Consumers brought a class action against ten automobile dealerships operating under the "Medved" name and their owner John Medved, alleging violations of the Colorado Consumer Protection Act (CCPA). Plaintiffs alleged that Medved's sales documents failed to disclose the price and existence of various dealer-added aftermarket products, injuring Plaintiffs who paid for those products. Plaintiffs sought certification of two classes: one which included customers who paid for the add-ons but that were never installed, and another class for those who paid for the add-ons but who were unaware of them due to Medved's sales documents. The trial court determined that Plaintiffs could prove causation and injury in their CCPA claims with circumstantial evidence. However, the trial court did not consider whether the individual evidence presented by Medved rebutted the class-wide inferences of causation and injury which was crucial to certification of both classes. The appellate court concluded that the trial court erred by not rigorously analyzing the evidence presented by Medved to refute Plaintiffs' theories of liability. Upon review, the Supreme Court affirmed the appellate court, and remanded the case back to the trial court for further analysis to determine "to its satisfaction whether Plaintiffs could establish causation and injury.