Boling

INTRODUCTION

Mark Boling appeals from the judgment in his action against respondent DTG Operations, Inc., which operates Dollar Rent A Car (Dollar). Boling sued Dollar under California’s Unfair Competition Law (UCL) and the Consumer Legal Remedies Act (CLRA), claiming he was overcharged and misled as to a tax he had to pay on a car he rented at the Phoenix, Arizona, airport in December 2011. The trial court granted Dollar’s motion for summary judgment and entered judgment in its favor against Boling. We affirm. Boling did not present evidence to create a triable issue of fact as to his damages under either the UCL or the CLRA, after Dollar made a prima facie case that he had not been damaged. Without evidence of damages, Boling does not have standing to sue under either statute. The court correctly granted summary judgment in Dollar’s favor.

FACTS

In December 2011, Boling went onto the CarRentals.com website to check the price of rental cars at the Phoenix airport. After viewing his options, he went to the 1 Dollar website to reserve a mid-sized car for 24 hours. The estimated total price quoted to him on the website included an amount for a tax on car rentals imposed by…