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MAROONE CHEVROLET, LLC d/b/a MAROONE CHEVROLET v. GERMAN ALVARADO

Citation: Not availableDocket: 21-0485

Court: District Court of Appeal of Florida; July 6, 2022; Florida; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this case, Maroone Chevrolet, LLC appealed a final judgment awarding German Alvarado damages related to the purchase of two vehicles. Alvarado's claims included violations of the Florida Unfair and Deceptive Trade Practices Act (FDUTPA), the Florida Motor Vehicle Retail Sales Finance Act, and fraud in the inducement. The Circuit Court initially awarded damages for the Second Truck under these statutes. Maroone contested these awards, arguing that the damages for FDUTPA were consequential rather than actual, and that incorrect finance charge calculations invalidated claims under the Retail Sales Finance Act. The appellate court agreed, reversing the damages awarded for Counts 2 and 3 due to a lack of competent evidence and improper calculations. However, the court affirmed the damages for fraud in the inducement related to the Second Truck, as there was sufficient evidence supporting the claim. The case was remanded for further proceedings, specifically to adjust the prejudgment interest award. The court's decision was a partial affirmation, reversal, and remand, reflecting the complexities of statutory interpretations and the evidentiary requirements for claims under these legal frameworks.

Legal Issues Addressed

Finance Charges under the Florida Motor Vehicle Retail Sales Finance Act

Application: The court found that Alvarado's incorrect calculation of finance charges invalidated his claims under sections 520.07 and 520.08, leading to the reversal of damages awarded under Count 3.

Reasoning: The court agreed, noting two key reasons for the failure of Alvarado’s claims: the absence of delinquency and the improper finance charge calculations.

Fraudulent Inducement

Application: The jury found sufficient evidence to support Alvarado's claim of fraudulent inducement regarding the Second Truck, affirming the damages awarded under Count 4.

Reasoning: The jury found that Maroone's statements could have impeded Alvarado's informed decision regarding the purchase.

Reversal of Jury Verdict

Application: The court reversed the jury's verdict on Counts 2 and 3 due to a lack of competent evidence and incorrect legal reasoning, directing judgment in favor of Maroone.

Reasoning: The jury’s verdict on Count 3 was deemed flawed due to incorrect calculations, lacking competent, substantial evidence.

Violation of the Florida Unfair and Deceptive Trade Practices Act (FDUTPA)

Application: The court agreed with Maroone's appeal that the damages awarded under section 501.976 were consequential rather than actual damages, which are not recoverable under the statute.

Reasoning: In the appeal, Maroone contested the jury's award under section 501.976, arguing that the awarded amount represented consequential damages rather than actual damages permissible under the statute.