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State ex rel. Corbin v. Tucson Public Auction, Inc.

Citations: 147 Ariz. 213; 709 P.2d 570; 1985 Ariz. App. LEXIS 720Docket: No. 2 CA-CIV 5332

Court: Court of Appeals of Arizona; August 1, 1985; Arizona; State Appellate Court

Narrative Opinion Summary

This case involves an appeal following a judgment in favor of the defendants, Tucson Public Auction, Inc. and Jimmy GMC, Inc., and their officers, accused of consumer fraud under the Arizona Consumer Fraud Act. The attorney general sought an injunction, alleging misrepresentations in two sales: a diesel GMC pickup truck and a motor home. The trial court ruled in favor of the defendants, but the appellate court reviewed the judgment, emphasizing its ability to overturn findings only if clearly erroneous. The appellate court identified errors in the trial court's acceptance of testimony and findings, specifically regarding the towing capacity and fuel efficiency misrepresentations in both transactions. The court noted that the representations made by the defendants were misleading and constituted consumer fraud, as they influenced the buyers' decisions. Consequently, the appellate court reversed the judgment, directing the trial court to provide injunctive relief and other remedies, including civil penalties, damages, and attorney's fees. This decision underscores the legal requirement for accuracy in representations made by sellers under A.R.S. 44-1522(A), highlighting the importance of truthful disclosure in consumer transactions to prevent deceptive practices.

Legal Issues Addressed

Arizona Consumer Fraud Act Violation

Application: The defendants committed consumer fraud by misrepresenting the diesel truck's towing capacity and the motor home's fuel efficiency.

Reasoning: In this case, the appellees committed consumer fraud by selling the Grippes a truck unsuitable for towing and misrepresenting the fuel economy of a mini-motor home.

Interpretation of Consumer Fraud and Misrepresentation

Application: Misrepresentation of product capability and performance is actionable under consumer fraud laws, especially when buyers rely on those representations.

Reasoning: If a seller voluntarily provides fuel economy or towing capability representations that a buyer relies upon, those representations must be truthful to avoid violating A.R.S. 44-1522(A), which prohibits deceptive practices in sales.

Reversal and Remand for Injunctive Relief

Application: The appellate court reversed the trial court's judgment and directed the trial court to provide injunctive relief and other remedies due to the erroneous findings.

Reasoning: The appellate court found the evidence contradictory and reversed the judgment, directing the trial court to grant injunctive relief, civil penalties, damages, and attorney’s fees on appeal.

Standard of Review for Appellate Court

Application: The appellate court can overturn the trial court's findings only if they are clearly erroneous.

Reasoning: The appellate court emphasized that it could only overturn the trial court's findings if they were clearly erroneous, and noted that additional findings could be implied to support the judgment if they were reasonably supported by the evidence.