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Boise Dodge, Inc. v. Clark

Idaho Supreme Court
453 P.2d 551 (1969)


Facts

Clark (defendant) purchased an automobile from Boise Dodge, Inc. (Boise) (plaintiff), a dealership. The odometer on the car showed 165 miles and was described by Boise’s salesman as “new.” In fact, however, the car was a “demonstrator” and Boise’s general manager knew that the odometer had been set back from 6,968 miles. To pay for the car, Clark traded in an old car worth $1,100 and issued checks for $500 and $1,562 for the balance of the purchase price. Clark later discovered that the car was actually “used” and stopped payment on the checks. Boise brought suit in Idaho state court against Clark to recover the value of the stopped checks ($2,062). Clark counterclaimed for damages for breach of contract and deceit, as well as punitive damages. The case was tried before a jury. The jury was instructed that it could award punitive damages to Clark, but that the award of punitive damages must bear a “reasonable relation” to any actual damages suffered by Clark. The jury awarded $2,062 in damages to Boise. The jury also awarded Clark $350, the difference between the value of the car as represented by Boise ($2,400) and the actual value of the car ($2,050). The jury also awarded Clark $12,500 in punitive damages. The award of punitive damages was affirmed by the appellate court, and Boise appealed.

Rule of Law

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Issue

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Holding and Reasoning (McQuade, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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