Sanchez v. Rains Precision Motorsports, Inc.
2025 COA 40. No. 24CA0725. Colorado Motor Vehicle Repair Act of 1977—Repairs on a Motor Vehicle—Negligence—Judgment Notwithstanding the Verdict—Sufficiency of Evidence.
April 17, 2025
In August 2021, Sanchez brought his truck to Rains Precision Motorsports, Inc. (RPM) for repairs and parts replacement. RPM estimated that the work would cost $6,000, which Sanchez agreed to pay, and he paid $1,040 up front. Sanchez supplied some of the replacement parts himself. In December 2021, RPM told Sanchez that the truck was ready and that the repairs would cost about $12,040. Sanchez went to get his truck the next day, but it wasn’t ready because exhaust system repairs hadn’t been performed. Sanchez agreed to pay the $12,040 and allowed RPM to finish the repairs. In March 2022, RPM told Sanchez that it had completed the repairs. Sanchez picked up his truck, but while driving home, the truck’s torque converter, which RPM had installed, began making noise. RPM told Sanchez to return the truck to be checked, which Sanchez did. RPM then retained possession of the truck until March 29, 2022, when the truck was stolen from RPM’s lot. Sanchez recovered his truck in August 2022. He then sued RPM for violations of Colorado’s Motor Vehicle Repair Act (CMVRA), CRS §§ 42-9-101 to -113; and for negligence, alleging that RPM failed to exercise reasonable care to protect the truck from theft. Sanchez sought damages of $7,611 on his CMVRA claim and $13,000 for the alleged value of his truck on his negligence claim. RPM moved for summary judgment, which the district court denied. A jury later determined that RPM violated the CMVRA and was negligent. It awarded Sanchez $7,611 on the CMVRA claim and $8,216.36 on the negligence claim. The court then trebled the damages on the CMVRA claim to $22,833. RPM moved for judgment notwithstanding the verdict (JNOV), which the district court denied.
On appeal, RPM contended that the district court erred by denying its motion for JNOV. It maintained that the CMVRA doesn’t apply to the work it did on Sanchez’s truck because that work constituted uncovered modifications or enhancements to the truck’s performance. RPM apparently reasoned that the camshaft, exhaust system parts, and torque converter it installed only made the truck’s engine louder and more powerful, so it didn’t make “repairs.” However, Sanchez’s truck had problems that needed to be fixed for it to run properly, so RPM’s work to fix those problems meets the commonly understood meaning of “repairs.” Further, much of RPM’s work on the truck was parts replacement, which is expressly included in the definition of “repairs on a motor vehicle.” And to the extent RPM argued that, because the parts Sanchez provided were aftermarket parts that increased the engine’s sound and performance, they weren’t replacement parts within the meaning of the CMVRA, it cited no authority excluding such parts from the meaning of “parts replacement.” Therefore, viewing the evidence in the light most favorable to the jury’s verdict, RPM performed work constituting “repairs” within the meaning of the CMVRA.
RPM also argued that the district court erred by denying its motion for JNOV because Sanchez’s truck isn’t a “motor vehicle” under the CMVRA since the parts it installed on the truck, as requested by Sanchez, made the truck not legal for street use under 42 USC § 7522(a)(3)(A). However, Sanchez’s 2003 Chevy Silverado SS truck was clearly classified as a “motor vehicle” when manufactured and sold, and its intended use was for traveling on public highways. That didn’t change when he had RPM repair his truck and replace some of its parts. Whether Sanchez could do so lawfully under the statutes RPM cited is beside the point.
RPM further asserted that the district court erred by denying its motion for JNOV because the jury’s negligence verdict isn’t supported by sufficient evidence. However, there was evidence from which the jury could have reasonably concluded that Sanchez met his burden of proving negligence by a preponderance of the evidence, including RPM’s owner’s testimony about several instances of theft on and around its premises, and the owner’s admission that RPM increased its security measures after Sanchez’s truck was stolen. Accordingly, the district court didn’t err by denying RPM’s JNOV motion.
Lastly, RPM contended that there was insufficient evidence to support the jury’s damages award on the negligence claim. RPM asserted that there wasn’t evidence that Sanchez suffered any damages because he recovered his truck and didn’t prove diminution in its value from the theft. Here, while Sanchez didn’t testify to the exact diminution in the truck’s value, there was sufficient evidence from which the jury could reasonably have estimated the loss, including the Kelley Blue Book value of the truck in good condition and evidence of the damage to the truck after the theft.
The court of appeals granted Sanchez’s request for an award of his appellate attorney fees under § 42-9-113.
The judgment was affirmed and the case was remanded to the district court for it to determine the reasonable amount of attorney fees Sanchez incurred on appeal to defend his judgment on the CMVRA claim.