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Ronald F. Fleming v. Jim Murphy

Citation: Not availableDocket: W2006-00701-COA-R3-CV

Court: Court of Appeals of Tennessee; July 19, 2007; Tennessee; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

The case involves a plaintiff who purchased a 1964 Chevrolet Corvette advertised on eBay as being in excellent condition. The plaintiff brought claims against the defendants, who facilitated the sale, alleging violations under the Tennessee Consumer Protection Act (TCPA), negligent misrepresentation, and breach of contract after discovering significant rust damage following the purchase. The defendants were granted summary judgment by the trial court, a decision later affirmed by the Court of Appeals. The court emphasized the 'as is' nature of the sale, noting that the plaintiff failed to exercise due diligence by declining a professional inspection despite visible issues during the test drive. Under the TCPA, the court found no causal link between the alleged deceptive practices and the plaintiff's injury. Furthermore, the court ruled that the plaintiff did not rely reasonably on any misrepresentations, thus dismissing claims of fraudulent and negligent misrepresentation. The enforceability of the 'as is' clause in the bill of sale was upheld, and the breach of contract claim was dismissed, leading to an overall judgment in favor of the defendants.

Legal Issues Addressed

As-Is Clause Enforceability

Application: The court upheld the as-is clause in the sales contract, emphasizing the buyer's acknowledgment of the vehicle's condition and the signed bill of sale disclaiming warranties.

Reasoning: The trial court highlighted the importance of the 'as is' clause in the signed bill of sale, which was considered the sole written agreement.

Fraudulent Misrepresentation and Concealment

Application: The plaintiff's claims of fraudulent misrepresentation and concealment were unsuccessful due to lack of reasonable reliance on the defendants' representations.

Reasoning: Mr. Fleming did not reasonably rely on any misrepresentations from the Appellees, leading to the conclusion that his claims of fraudulent misrepresentation and concealment were unsuccessful.

Negligent Misrepresentation

Application: The court dismissed the negligent misrepresentation claims, finding that the plaintiff did not justifiably rely on the alleged false information.

Reasoning: The court reaffirmed its agreement with the trial court’s finding that Mr. Fleming did not justifiably rely on the alleged misrepresentations.

Summary Judgment Standard

Application: The court granted summary judgment to the defendants, finding no genuine issue of material fact as the plaintiff failed to exercise ordinary diligence in inspecting the vehicle before purchase.

Reasoning: The trial court found that Mr. Fleming, the plaintiff, did not exercise ordinary diligence regarding the facts of the case, leading to the granting of summary judgment in favor of the defendants.

Tennessee Consumer Protection Act (TCPA) Application

Application: The court ruled that the TCPA does not require reliance on misrepresentations, but the plaintiff did not demonstrate a causal link between the alleged violations and his injury.

Reasoning: The TCPA permits individuals who suffer ascertainable losses due to unfair or deceptive acts to seek damages. However, to succeed, plaintiffs must establish a causal link between the alleged violations and their injuries.