Young v. Toyota Motor Sales, U.S.A., 472 P.3d 990

Duane Young purchased a new 2014 Toyota Tacoma (≈$36,000) advertised to include an outside temperature display on the rearview mirror; the truck he bought lacked that feature.
Toyota’s website, advertising, and Monroney label for the 2014 Tacoma Limited package incorrectly listed the outside temperature display; the error persisted for ~2 months and affected 147 vehicles nationwide.
Toyota corrected its advertising, made corrected Monroney labels available, and offered affected buyers $100 (about 10× Toyota’s cost to install the gauge); Young rejected the offers and sued under Washington’s Consumer Protection Act (CPA).
At bench trial the court found Toyota’s affirmative misrepresentation had the capacity to deceive but found Young did not prove causation (the judge found Young’s claimed reliance not credible) and returned a defense verdict.
The Court of Appeals held materiality is required for a CPA deception claim and found the $10 feature immaterial to a $36,000 transaction; the Washington Supreme Court granted review.
The Supreme Court held materiality is not categorically required to satisfy the CPA’s first element for an affirmative misrepresentation, but affirmed the judgment because Young failed to prove causation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Must a misrepresentation be "material" to satisfy the CPA’s first element (unfair or deceptive act)?	Materiality not required; an affirmative misrepresentation that can deceive a substantial portion of the public suffices.	Federal FTC doctrine requires materiality; CPA should follow that rule.	Materiality is sufficient but not a categorical legal requirement for an affirmative misrepresentation under the CPA.
Did Toyota’s statements have the capacity to deceive a substantial portion of the public (first element)?	Yes — advertising and Monroney labels explicitly represented a feature that was not present.	The omission was trivial/financially immaterial (feature ≈$10), so no actionable deception.	The Court held Toyota’s affirmative misrepresentation had the capacity to deceive and satisfied the first element.
Did Young prove causation (that Toyota’s acts caused his injury)?	Young asserted he relied on the representation and was induced to purchase.	Young did not in fact rely; he was not charged for the feature and the trial judge found his reliance testimony not credible.	Young failed to prove causation; the trial court’s factual findings (no proven reliance/causation) were sustained.
Entitlement to attorney fees	Young requested fees following judgment.	Toyota opposed.	Request for attorney fees was denied.

Panag v. Farmers Ins. Co. of Wash., 166 Wn.2d 27 (2009) (lists the five elements of a private CPA claim and explains capacity-to-deceive test)
Hangman Ridge Training Stables, Inc. v. Safeco Title Ins. Co., 105 Wn.2d 778 (1986) (explains CPA purpose and capacity-to-deceive standard)
Indoor Billboard/Wash., Inc. v. Integra Telecom of Wash., Inc., 162 Wn.2d 59 (2007) (discusses causation under the CPA and limits of reliance)
Leingang v. Pierce County Med. Bureau, Inc., 131 Wn.2d 133 (1997) (when operative facts undisputed, unfair-or-deceptive is a question of law)
Klem v. Wash. Mut. Bank, 176 Wn.2d 771 (2013) (describes CPA’s broad scope and categories of actionable conduct)
Bain v. Metro. Mortg. Grp., Inc., 175 Wn.2d 83 (2012) (example of presumption that certain practices satisfy CPA’s first element)