Houston Independent Automobile Dealers Association March 2016 Issue: Floor Plans | Page 17
that she relied on any misrepresentations the dealership might have made about the car
because the sale was an "as is" sale. The appellate court refused to dismiss the claim under the
state UDAP statute. It concluded that the buyer could make a UDAP claim if she could prove
that the dealership's actions or statements had the capacity or tendency to deceive her and that
she suffered harm because of those statements. She did not have to show that she relied on the
statements; she only had to show that she might not have bought the car if the dealership had
not told her that the car had not incurred significant damage. The appellate court dismissed all
the claims against the repossessing creditor. The appellate court concluded that the creditor
was not liable under the state UDAP law because the buyer did not buy the car at the auction
and had no knowledge of any statement or disclosure the creditor or the auctioneer made about
damage to the car at the auction. The appellate court also dismissed the fraud and negligence
claims because the creditor did not owe a duty to the buyer to make sure the dealership
disclosed complete or accurate information to her when she bought the car from the dealership.
See Sain v. Adams Auto Group, Inc., 2016 N.C. App. LEXIS 58 (N.C. App. January 5, 2016).
So there’s this month’s roundup! Stay legal, and we’ll see you next month.
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Tom ([email protected]) and Nikki ([email protected]) are partners in the law firm of Hudson Cook, LLP. Tom has written several books
and is the publisher of Spot Delivery®, a monthly legal newsletter for auto dealers. He is Editor in Chief of CARLAW®, a monthly report of
legal developments for the auto finance and leasing industry. Nikki is a contributing author to the F&I Legal Desk Book and frequently writes for
Spot Delivery. For information, visit www.counselorlibrary.com. Copyright CounselorLibrary.com 2015, all rights reserved. Single publication
rights only, to the Association. (2/16). HC# 4848-8454-3277.