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Owens v. Samkle Automotive Inc.

United States Court of Appeals for the Eleventh Circuit
425 F.3d 1318 (2005)


Facts

Glendale Owens (plaintiff) bought a used car from Marlin Mazda (Mazda), a car dealership owned and operated by Samkle Automotive Inc. (Samkle) (defendant). At the time of sale, Mazda gave Owens a number of forms to sign. However, Mazda did not provide Owens with the car’s original title as required by the Motor Vehicle Information and Cost Savings Act (Odometer Act), 49 U.S.C. § 37201 et seq. Additionally, the forms provided by Mazda were not the official forms required by state law and did not include certain mandatory disclosures. Nonetheless, by signing the forms provided, Owens obtained ownership of the car without ever seeing the original title. Owens later learned that the car was previously a short-term rental car owned by Hertz. Owens sued Samkle in federal district court, claiming that Samkle had violated provisions of the Odometer Act with the intent to defraud. Owens alleged that Mazda had intentionally not provided the original title and that Owens never would have bought the car if she had known it was previously used as a short-term rental car. The district court dismissed Owens’s complaint, holding that recovery under the Odometer Act was only permissible if the defendant’s intent to defraud was specifically related to the car’s mileage. Owens appealed.

Rule of Law

Issue

Holding and Reasoning (Per curiam)

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