Taylor v. Honda Motorcars, Inc.

Eric Taylor (plaintiff), in his name alone, leased a 2017 Honda Accord from Motorcars, Inc. (defendant). Unbeknownst to Eric and his wife, Marcia (plaintiff), a few hours before Eric took possession, another Honda Accord had been stolen from Motorcars. Motorcars reported the theft to the police. Motorcars mistakenly assigned the same temporary license to the Honda leased by Eric and the stolen vehicle. Later, when Marcia was driving Eric’s vehicle, the police pulled her over and detained her and the Taylors’ daughter, who was a passenger in the vehicle. The plate error was discovered, and no criminal charges were filed against the Taylors. Eric returned the vehicle, Motorcars returned Eric’s money, and the parties agreed to terminate the lease. The Taylors sued Motorcars for breach of contract, alleging that Motorcars breached the lease agreement by placing the incorrect temporary license plate on their car, which resulted in the car’s seizure by the police. The Taylors sought only emotional-distress damages allegedly arising from the humiliation caused by the police’s detaining Marcia and their daughter when the car was seized. The Taylors argued that because Marcia and their daughter were intended beneficiaries of the lease agreement, they were entitled to assert a contractual claim for emotional-distress damages. In support, the Taylors alleged that they advised Motorcars that the vehicle was to be used by Marcia as the family vehicle and that Marcia was intimately involved in its selection and purchase, but their affidavits only asserted that the Motorcars representatives knew that the car was being leased for Marcia’s use. The trial court granted summary judgment for Motorcars, finding that the Taylors failed to generate a genuine issue of fact for trial. The Taylors appealed.