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Osteen v. Morris
Citations: 481 So. 2d 1287; 11 Fla. L. Weekly 259Docket: 85-823
Court: District Court of Appeal of Florida; January 22, 1986; Florida; State Appellate Court
In the case of Gary Osteen v. Curtis Morris, the District Court of Appeal of Florida addressed an appeal concerning a final judgment from the Volusia County Court, certified as having great public importance. Curtis Morris, the customer, delivered his vehicle to Osteen's repair shop for repairs, but was not provided with a written estimate or notice of the right to one, as required by section 559.905 of the Florida Statutes. After initially authorizing repairs estimated between $500 and $700, additional work was needed, leading to a second oral estimate of $1,490.90, which Morris also authorized. However, he only paid $750 and refused to pay the remaining balance, prompting the shop to file a claim for the unpaid amount. Morris counterclaimed for the $750 he had already paid. The trial court ruled that due to Osteen's failure to comply with the Florida Motor Vehicle Repair Act, Morris was not liable for the full repair cost, and the shop owed him $700.50. The court certified several questions regarding the constitutionality of the statute, the necessity of proving actual loss for an injury claim under the statute, the applicability of equitable principles like quantum meruit, and the interpretation of statutes that deviate from common law. The court concluded that the Florida Motor Vehicle Repair Act is constitutional, as it does not impair existing contracts. It also highlighted that the Act requires written estimates for repairs exceeding $50, which were not provided in this case. The shop violated sections 559.901-923 of the Florida Statutes, resulting in a customer paying for services due to the shop's noncompliance. The customer received $1,490 worth of repair work for a cost of $750, but if the customer is held liable, it undermines the legislative intent behind the statute. Quantum meruit, a legal doctrine imposing liability for services rendered in the absence of an express agreement, is limited by this consumer protection statute to prevent repair shops from bypassing requirements for written estimates or waivers. The statute aims to protect consumers from misunderstandings associated with oral estimates, which can lead to disputes after repairs are completed. The trial court's decision, favoring the defendant shop, aligns with the statutory intent, despite concerns about fairness to the shop. The court emphasizes that issues of justice for repair shops should be addressed to the legislature, not through judicial modification of the statute's application. The trial court's ruling is affirmed.