Greenwood v. Quality Motor Cars by Butch Miller
2016 Ohio 8172
| Ohio Ct. App. | 2016Background
- Greenwood bought a 2002 Chevrolet S-10 from Quality Motor Cars on Dec. 30, 2011; sale included a "3,000 mile / three-month deluxe warranty" per the sales contract.
- Greenwood experienced breakdowns almost immediately, had the vehicle inspected by the dealer’s outside shop (no problem found), then by Whiteside Chevrolet which said engine and transmission needed replacement (~$6,000).
- Greenwood sued Quality Motor Cars in Belmont County Small Claims Court seeking $2,900 (half of repair cost), alleging he was sold a warranty the truck was ineligible to receive and the dealer failed to honor it.
- Evidence at hearing: sales contract referencing the deluxe warranty; A1 repair invoice showing parts ($1,250) and labor ($2,025) and that the warranty paid $450; Whiteside invoice stating repairs not covered by extended warranty.
- Trial court awarded Greenwood $2,900 plus interest. Quality Motor Cars appealed, arguing (1) Greenwood sued the wrong party (warranty provider should have been sued) and (2) the judgment was against the manifest weight of the evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper party for alleged warranty enforcement/breach | Greenwood: dealer sold and received payment for a deluxe warranty it knew the vehicle was ineligible for; dealer’s conduct is the basis of the claim | Quality: action to enforce warranty should be against the warranty provider, not the seller/dealer | Court: action targeted dealer’s conduct in selling a warranty the buyer didn’t receive; dealer is proper defendant |
| Manifest weight / sufficiency of evidence that dealer breached or engaged in deception under R.C. 1345.02 | Greenwood: contract and invoices show he paid for deluxe warranty and did not receive its benefits; dealer’s representations induced purchase | Quality: Greenwood’s testimony lacked credibility; factual inconsistencies (odometer, ability to drive miles with alleged damage) undermine claim | Court: record contains competent, credible evidence of breach and of a deceptive practice; judgment not against manifest weight |
Key Cases Cited
- Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (definition of abuse of discretion)
- Eastley v. Volkman, 132 Ohio St.3d 328 (2012) (explanation of manifest-weight review and that weight depends on effect in inducing belief)
- Thompkins v. Ohio, 78 Ohio St.3d 380 (1997) (distinction between sufficiency and weight of the evidence)
- State v. Martin, 20 Ohio App.3d 172 (1983) (framework for weighing evidence and resolving conflicts)