Travis Gonzales v. Carmax Auto Superstores, LLC

Travis Z. Gonzales sued CarMax Auto Superstores, LLC (“CarMax”), a used car retailer, after experiencing problems with a vehicle he purchased at one of its lots. Gonzales alleged violations of four Califor nia 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”). Gonzales’s claims under the CLRA and UCL were both based on Car-Max’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 Gonzales’s fraud and Song-Beverly claims and granted Car-Max summary judgment on his CLRA and UCL claims.

The key issue before us is whether 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 a “completed inspection report” under California law. Because we conclude that it is not, we reverse the district court’s decision to grant summary judgment to CarMax,on Gonzales’s CLRA…