Jennifer Bark v. Jason Keen

CourtCourt of Appeals of Texas
DecidedDecember 15, 2020
Docket01-19-00997-CV
StatusPublished

This text of Jennifer Bark v. Jason Keen (Jennifer Bark v. Jason Keen) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jennifer Bark v. Jason Keen, (Tex. Ct. App. 2020).

Opinion

Opinion issued December 15, 2020

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-19-00997-CV ———————————

JENNIFER BARK, Appellant

V.

JASON KEEN, Appellee

On Appeal from the County Civil Court at Law No. 3 Harris County, Texas Trial Court Case No. 1122453

MEMORANDUM OPINION

Appellant, Jennifer Bark, challenges the trial court’s rendition of summary

judgment in favor of appellee, Jason Keen, in Keen’s negligence suit against her for

property damage arising from an auto collision. In her sole issue, Bark argues that the trial court erred in granting summary judgment because Keen did not

conclusively establish his claim for damages based on a diminution in the market

value of his repaired car.

We reverse and remand.

Background

In his petition, Keen alleged, that, on April 24, 2018, while he was driving his

Chevrolet Corvette Stingray on Farm-to-Market Road 1960 in Harris County, Bark,

who was driving behind him, failed to stop and drove her car into the back of the

Corvette. Bark stipulated to liability and paid the cost of repairs, which totaled

$9,557.05. Keen alleged that, despite the repairs, the market value of the Corvette

was diminished by $11,411.10 based on the car having collision and repair history.

After Bark failed or refused to reimburse him for the asserted diminished value,

Keen brought a negligence claim against her, seeking $11,411.10 in damages.

Keen moved for a summary judgment on his claim, asserting that he was

entitled to judgment as a matter of law because liability was undisputed and his

evidence established that Bark’s negligence diminished the market value of the

Corvette as alleged. Keen attached to his motion a copy of his purchase contract,

reflecting that, on November 13, 2017, he purchased the 2014 Corvette, with an

odometer reading of 18,595, from Corvettes of Houston, Inc., for $53,669.06. Keen

also attached his own affidavit, in which he testified that, at the time of purchase, the

2 car had no prior damage. However, four months after purchase, in an unrelated

matter on March 26, 2018, a motorist drove into the back of the Corvette (“previous

collision”). The motorist stipulated to liability and paid the cost of repairs, which

totaled $4,723.35. The Corvette was repaired at a Chevrolet dealership. On April

24, 2018, shortly after Keen drove away from the dealership in the repaired Corvette

and was stopped at a traffic light, Bark drove her car into the back of the Corvette

(“instant collision”). And, the Corvette was again repaired.

Keen retained an expert, Justin Petty, to appraise the diminished market value

of the repaired Corvette attributable to each of the collisions. Petty determined that

the previous collision diminished its market value by $6,713.00, and Keen settled

his claim with the motorist. With respect to the diminution-in-value attributable to

the instant collision, Keen attached Petty’s affidavit and supporting expert report.

In his affidavit, Petty testified that he has been an automobile appraiser for 22

years and follows the industry’s Uniform Standards of Professional Appraisal

Practice (“USPAP”). He has appraised 15,000 vehicles and has performed 4,000

value assessments focusing on “inherent diminished trade-in value.” He has testified

as an expert witness on 30 occasions, has authored various books and articles, and

has presented seminars on the marketability of vehicles damaged in collisions.

Petty stated in his affidavit that his objective is to determine the “inherent

diminished value” of the subject vehicle, which he defined as:

3 the difference in selling price, in a specific market, of a damaged vehicle that has been repaired and restored to industry standard as compared to a similar vehicle that has never been damaged. This Inherent Diminished Value is the result of a prospective buyer’s perception that a vehicle with an accident history is not as valuable as another vehicle of the same year, make, model, condition and mileage, which has never been damaged.

With respect to his methodology, Petty stated:

9. In calculating diminished value I determine the vehicle’s pre-crash market value. I then determine the vehicle’s post-repair market value. The diminished value is the amount by which the vehicle’s pre-crash market value exceeds its post-repair market value. A number of factors affect a vehicle’s Loss of Market Value after sustaining a collision and undergoing subsequent repairs. These include, but are not limited to: market demand for the vehicle (its year, make, model, mileage and condition); the amount, type and severity of damage; the specific area(s) of damage to the vehicle; the quality of the repairs and replacement parts; adjuster and body shop oversight; and consumer beliefs, i.e., that vehicles that have been involved in an accident are more likely to present future problems, with associated costs, because of the structural, mechanical, electrical, safety or cosmetic repairs that had to be made. It is well-known that the vast majority of collision repair facilities cannot duplicate manufacturer tolerances or quality. .... 11. In determining diminished value I review the repair facility’s estimate of record. . . . After determining that a vehicle owner’s chosen repair facility has properly identified the damages to the car, and properly performed the repairs in accordance with ASE (Automotive Service Excellence) or I-CAR collision repair industry standards, I make numerous calculations to arrive at the pre-loss (before crash) market value of the damaged vehicle. I weight the repairs proportionally with respect to the degree by which they would affect the vehicle’s integrity, function, safety, appearance, value and warranty. 12. I also review and take into account any prior accident records. From these records I determine any prior diminished value. The market 4 value of the vehicle immediately prior to the accident in question is reduced by the amount of diminished value attributable to any prior accidents. . . .

Petty noted that he does not physically inspect the subject vehicle. Rather, he

reviews photographs and discusses the condition of the vehicle with the owner. He

develops his data by conducting phone interviews, field research, peer consultations,

and market surveys. He also utilizes data from published guides, such as the

National Automobile Dealers Association (“NADA”) Guide.

With respect to the instant case, Petty testified that he was retained to evaluate

whether the market value of Keen’s 2014 Chevrolet Corvette Stingray Z51

convertible was diminished following the April 24, 2018 collision with Bark, which

caused damage requiring $9,557.05 in repairs. He noted that he did not inspect

Keen’s Corvette before or after the repairs attributable to the previous or instant

collisions. Rather, he reviewed photographs of Keen’s car and repair “estimate[s],”

which he attached, and he discussed the condition of the car with Keen.

With respect to applying his methodology in this case, Petty testified:

18. In this case, Mr. Keen’s vehicle had been involved in a prior accident on March 26, 2018. . . . I calculated the diminished value resulting from the first accident to be $6,713.00. I then determined what the market value of the Corvette would have been just prior to the second accident had it not been in a prior accident. That number was $44,750.00.

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