Julia Rose Nawrocki v. J&J Auto Outlet

CourtNew Jersey Superior Court Appellate Division
DecidedNovember 25, 2025
DocketA-3606-23
StatusUnpublished

This text of Julia Rose Nawrocki v. J&J Auto Outlet (Julia Rose Nawrocki v. J&J Auto Outlet) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Julia Rose Nawrocki v. J&J Auto Outlet, (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited . R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-3606-23

JULIA ROSE NAWROCKI, individually and on behalf of all others similarly situated,

Plaintiff-Respondent,

v.

J&J AUTO OUTLET, trading as AUTO CONCEPTS, MICHAEL GARRO and JOE GALLO,

Defendants-Appellants. __________________________

Argued September 11, 2025 – Decided November 25, 2025

Before Judges Berdote Byrne and Jablonski.

On appeal from an interlocutory order of the Superior Court of New Jersey, Law Division, Camden County, Docket No. L-0221-23.

Brian R. Griffin argued the cause for appellants (O'Toole Scrivo, LLC, attorneys; Kyle Vellutato and Brian R. Griffin, on the briefs).

Lewis G. Adler argued the cause for respondent (Lewis G. Adler and Perlman DePetris Consumer Law LLC, attorneys; Lewis G. Adler and Lee M. Perlman, of counsel; Paul DePetris, of counsel and on the brief).

PER CURIAM

Following leave to appeal, defendants challenge a trial court's order that

awarded partial summary judgment to plaintiff on two counts of her twelve-

count complaint and denied defendants' cross-motion for similar relief. In her

complaint, plaintiff contends defendants—J&J Auto Outlet, trading as Auto

Concepts, Michael Garro (Garro), and Joe Gallo (Gallo)—violated the

Consumer Fraud Act (CFA), N.J.S.A. 56:8-1 to -210, when they charged her a

"document fee" for the purchase of a motor vehicle without itemizing it, in

violation of the Automotive Sales Practice Regulations (ASP), N.J.A.C. 13:45A-

26B.2 to - 26B.3 (count two). She also claimed defendants violated the New

Jersey Truth-in-Consumer Contract, Warranty, and Notice Act (TCCWNA),

N.J.S.A. 56:12-15 by offering and entering into a consumer contract that

allegedly infringed upon "any clearly established legal right of a consumer or

responsibility of a seller . . . under State or Federal law" (count five).

Following our de novo review, we find the trial court incorrectly

concluded a regulatory violation alone represents a "per se" violation of the CFA

that would entitle a plaintiff to a judgment under it. Such a finding is not

consistent with our decision in Gross v. TJH Automotive Co., L.L.C., 380 N.J

A-3606-23 2 Super. 176, 185 (App. Div. 2005) in which we held that a regulatory violation

might be sufficient to satisfy one prong of the multi-factor test for a CFA

violation.

Considering our decision in Gross, we are not convinced the trial court

made sufficient findings on the question of whether the charged "document fee"

that provided the basis for the judgment violated N.J.A.C. 13:45A -26B.3.

Further, the trial court also did not address whether plaintiff proved an

ascertainable loss, nor did it consider whether there was a causative link between

any unlawful conduct and the ascertainable loss that would be required to

support a judgment under the CFA. Therefore, we vacate summary judgment

and remand this matter to the trial court to make findings as to whether the

"document fee" charged violated N.J.A.C. 13:45A-26B.3 in light of our holding

in Gross. If the court determines a violation occurred that satisfies the CFA, it

must determine whether plaintiff suffered ascertainable loss and whether there

is a causative link between the violation and the ascertainable loss.

A-3606-23 3 I.

We glean the material facts from the summary judgment record and view

that evidence in the light most favorable to the non-moving parties. See

Comprehensive Neurosurgical, P.C. v. Valley Hosp., 257 N.J. 33, 71 (2024).

Plaintiff was interested in purchasing a pre-owned 2012 Dodge Ram from

defendants. After she visited their dealership several times, she inspected the

vehicle, test drove it, and negotiated a favorable price with the dealership's

salesperson. Early in the process, defendants provided her with a contract titled

"Buyer's Order" that listed the sale price and reflected two separate fees: a "title

and license fee" of $145 and a $299 "document fee."

The Buyer's Order described the "title and license fee" as an estimated fee

paid for clerical government compliance to transfer the vehicle. It also noted

the exact amount would not be known until ownership was transferred. The

Buyer's Order does not break down nor does it further describe the "document

fee" that is listed as a single line item on that agreement.

Plaintiff retained the Buyer's Order for several days. Ultimately, she

agreed to the purchase and a new Buyer's Order was prepared. Defendants used

a third-party software program to generate the final documents that, according

to defendants, ensured compliance with New Jersey regulations. The program,

A-3606-23 4 however, did not permit the breakdown of fees beyond what appeared on the

forms. Consistent with the original Buyer's Order, the new Buyer's Order listed

the $299 "document fee" and a $145 license fee.1 Plaintiff took delivery of the

vehicle.

Plaintiff commenced a putative class action lawsuit by filing a 328-

paragraph complaint asserting twelve separate causes of action against

defendants. Specifically, she sought recovery under the "used car lemon law

buyers guide" (count 1); classwide automotive sales practices (count 2);

classwide automotive advertising practices (count 3); classwide consumer fraud

violations (count 4); classwide TCCWNA violations (count 5); breach of

contract (count 6); breach of the covenant of good faith and fair dealing (count

7); promissory estoppel (count 8); negligent delivery of a defective used car

(count 9); relief under N.J.S.A. 2A:32-1, remedies of a person defrauded (count

10); classwide declaratory judgment (count 11); and claims against unnamed

parties (count 11).

Pertinent to this appeal, and in the counts alleging violations of the CFA,

she claimed the contract violated New Jersey regulations that required the

itemization of the document fee. Specifically, she alleged the dealer charged a

1 Plaintiff does not dispute the "title and license fee" was sufficiently itemized. A-3606-23 5 flat "document fee" without specifying the services performed and their

corresponding charges, if any. She also alleged the dealer failed to provide any

contract or other supporting documentation describing the services covered by

the fee.

Plaintiff accused defendants of violating the CFA through ASP regulation

(N.J.A.C. 13:45A-26B.3) and Motor Vehicle Advertising Practices (MVAP)

regulation (N.J.A.C. 13:45A-26A.4). Before discovery began, plaintiff moved

to certify a class on three counts in the complaint. Defendants opposed the

application and argued the Buyer's Order sufficiently itemized the document

service fees and did not violate the ASP, the CFA, nor the TCCWNA. The trial

judge granted preliminary class certification and observed:

Plaintiff here was charged . . . $299 for the document fee. The [B]uyer's [O]rder does not contain a description of what the document fee involves. It is alleged that this violates the [ASP, N.J.A.C. 13:45A- 26B.2].

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