Editor’s Note: Law Week Colorado edits court opinion summaries for style and, when necessary, length.
Sanchez v. Rains Precision Motorsports
Juan Sanchez owned a 2003 Chevrolet Silverado truck. In August 2021, Sanchez replaced the truck’s camshaft. Soon after, the engine started to make an unusual noise, and Sanchez was unable to fix the problem.
He brought his truck to Rains Precision Motorsports for repairs and replacement of parts the following month. He supplied some of the parts himself. The repair ended up costing more than double the estimate, which he agreed to pay. After he picked up the truck, it was still making an unusual noise. Sanchez brought the truck back, and it was subsequently stolen from RPM’s lot.
After recovering the truck, Sanchez sued RPM, alleging that RPM violated Sections 42-9-104(2)(a)(I) and 42-9-105(1) of the Colorado Revised Statutes. He also alleged that RPM was negligent under a bailment theory, alleging it failed to exercise reasonable care to protect Sanchez’s truck from theft. He sought $7,611 on his Colorado Motor Vehicle Repair Act claims and $13,000 on his negligence claim.
A jury found that RPM violated the CMVRA and was negligent. The jury awarded Sanchez $7,611 on the CMVRA claim and $8,216.36 on the negligence claim. The court trebled the damages on the CMVRA claim to $22,833.
RPM filed a motion for judgment notwithstanding the verdict, arguing that the CMVRA’s protections for customers didn’t apply to RPM’s work on Sanchez’s truck and that insufficient evidence supported the jury’s negligence verdict. The district court denied RPM’s motion.
RPM argued that the district court erred by denying its motion for JNOV because the CMVRA doesn’t apply to RPM’s work on Sanchez’s truck and the jury’s negligence verdict wasn’t supported by sufficient evidence. The Colorado Court of Appeals rejected both arguments.
The appeals court affirmed and remanded the case to the district court to determine the reasonable amount of attorney fees Sanchez incurred on appeal.