KAUFMAN v. GUEVARA

CourtCourt of Appeals of Arizona
DecidedDecember 11, 2025
Docket1 CA-CV 24-0518
StatusPublished
AuthorMichael J. Brown

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

Bluebook
KAUFMAN v. GUEVARA, (Ark. Ct. App. 2025).

Opinion

IN THE ARIZONA COURT OF APPEALS DIVISION ONE

DAVID KAUFMAN, an adult individual, and PHOENIX CORVETTE SALES LTD, Plaintiffs/Appellants,

v.

CHRISTINA GUEVARA; PINNACLE NISSAN, INC.; and NISSAN NORTH AMERICA, INC., Defendants/Appellees.

No. 1 CA-CV 24-0518 FILED 12-11-2025

Appeal from the Superior Court in Maricopa County No. CV2020-055036 The Honorable Melissa Iyer Julian, Judge

AFFIRMED IN PART; VACATED AND REMANDED IN PART

COUNSEL

Maynard Cronin Erickson & Curran, P.L.C., Phoenix By Daniel D. Maynard, Douglas C. Erickson Counsel for Plaintiffs/Appellants

Clark Hill PLC, Scottsdale By Darrell E. Davis, Ryan J. Lorenz Counsel for Defendant/Appellee Pinnacle Nissan, Inc.

Klein Thomas Lee & Fresard, Phoenix By Paul R. Lee, Brandon L. Boxler (pro hac vice) Counsel for Defendants/Appellees Nissan North America, Inc. KAUFMAN, et al. v. GUEVARA, et al. Opinion of the Court

OPINION

Judge Michael J. Brown delivered the opinion of the Court, in which Presiding Judge Anni Hill Foster and Judge Paul J. McMurdie joined.

B R O W N, Judge:

¶1 Arizona Revised Statutes § 28-3475 prohibits a vehicle owner from knowingly allowing anyone to drive the vehicle on a highway who is not properly authorized to drive. The primary question before us is whether violating that law constitutes negligence per se. Because we answer the question affirmatively, we vacate the superior court’s grant of summary judgment in favor of the vehicle owner in this case and remand for further proceedings.

BACKGROUND

¶2 In March 2020, Christina Guevara visited Pinnacle Nissan, Inc. (“Pinnacle”) to buy a car. She told a sales representative she did not have a valid driver’s license and instead presented an Arizona identification card. Pinnacle did not ask and Guevara did not disclose why she did not have a driver’s license, which was suspended for violations of driving under the influence. Ultimately Guevara agreed to buy a 2019 Nissan Sentra. Because she did not qualify for financing independently, Pinnacle required a co-signer. Guevara then signed various documents, including a conditional delivery confirmation and acknowledgment, a promissory note, and an application for title and registration. The co- signer, who never had a valid driver’s license and does not drive, also signed the documents. Until final approval by a financial institution, Pinnacle would retain legal ownership of the car.

¶3 After accepting a down payment, Pinnacle gave Guevara the keys to the car, and she drove away. A few days later, the car required maintenance and Pinnacle told Guevara to bring it back to the dealership. While driving to the dealership without a license and under the influence of alcohol, she crashed into a car driven by David Kaufman and owned by Phoenix Corvette Sales LTD (collectively, “Kaufman”).

¶4 As relevant to this appeal, Kaufman sued Pinnacle and Nissan North America, Inc. (“Nissan”) for negligent entrustment, alleging Pinnacle

2 KAUFMAN, et al. v. GUEVARA, et al. Opinion of the Court

violated its duty to Kaufman and the public when it entrusted the car to Guevara and failed to investigate why neither she nor the co-signer lacked valid driver’s licenses. After discovery, Pinnacle moved for summary judgment, asserting Kaufman could not make a prima facie case because he had no evidence showing (1) Guevara had a physical or mental condition rendering her incompetent to drive safely, or (2) Pinnacle knew or should have known about Guevara’s incompetence when it entrusted her with the car. Pinnacle did not dispute that it owned the car. Nissan also requested summary judgment, asserting Kaufman neither identified any specific theory of agency nor provided any facts that an agency relationship existed between Nissan and Pinnacle.

¶5 The superior court granted both motions, explaining in part Kaufman had cited no Arizona law imposing an affirmative duty on an auto dealer to ask why a potential car buyer lacks a valid driver’s license, and the “mere fact that the vehicle owner is aware that the entrusted driver is unlicensed is insufficient, by itself, to establish liability.” The court then concluded that because the claim against Nissan was based solely on vicarious liability for Pinnacle’s conduct, Nissan was not liable. Following entry of a judgment entered under Arizona Rule of Civil Procedure 54(b), Kaufman timely appealed, and we have jurisdiction under A.R.S. § 12-2101(A)(1).

DISCUSSION

¶6 Summary judgment is appropriate when the moving party “shows that there is no genuine dispute as to any material fact and the moving party is entitled to judgment as a matter of law.” Ariz. R. Civ. P. 56(a). We review a grant of summary judgment de novo, including the superior court’s application of the law and whether there were genuine issues of material fact, viewing the facts and reasonable inferences in the light most favorable to the non-moving party. Takieh v. O’Meara, 252 Ariz. 51, 56, ¶ 11 (App. 2021).

A. Vicarious Liability - Nissan

¶7 Nissan argues Kaufman provides no basis to support holding it vicariously liable for any asserted negligence by Pinnacle. See Urias v. PCS Health Sys., Inc., 211 Ariz. 81, 88, ¶ 38 (App. 2005) (“[A] court must find that the principal had the right to control the purported agent’s conduct for the transaction at issue.”). The superior court did not address the alleged agency relationship between Pinnacle and Nissan because it concluded that if the agent is not liable, neither is the principal. But we will affirm the

3 KAUFMAN, et al. v. GUEVARA, et al. Opinion of the Court

court’s ruling for any reason supported by the record. See Glaze v. Marcus, 151 Ariz. 538, 540 (App. 1986) (affirming a grant of summary judgment while acknowledging this court “will affirm the trial court’s decision if it is correct for any reason, even if that reason was not considered by the trial court”). Given that Kaufman has provided no evidence establishing an agency relationship between Pinnacle and Nissan, there is nothing attaching liability to Nissan. We therefore affirm the superior court’s grant of summary judgment for Nissan.

B. Negligence Per Se - Pinnacle

¶8 After our initial review of the appellate briefing, we ordered the parties to provide supplemental briefs addressing whether a violation of § 28-3475 constitutes negligence per se. Section 28-3475 states that “[a] person shall not authorize or knowingly permit a motor vehicle owned by that person or under that person’s control to be driven on a highway by any other person who is not authorized under this chapter or in violation” of Chapter 8, titled “Motor Vehicle Driver Licenses.” A person who violates § 28-3475 is subject to a civil penalty. See A.R.S. § 28-3471.

¶9 Kaufman should have raised § 28-3475 in the superior court, which understandably focused its ruling based on legal arguments the parties presented. Typically, failure to raise the issue would result in waiver on appeal. See Cont’l Lighting & Contracting, Inc. v. Premier Grading & Utils., LLC, 227 Ariz. 382, 386, ¶ 12 (App. 2011) (Generally, “legal theories must be presented timely to the trial court so that the court may have an opportunity to address all issues on their merits.”). But “waiver is a procedural concept that we do not rigidly employ in a mechanical fashion,” and we may exercise our discretion to address issues otherwise waived. Azore, LLC v. Bassett, 236 Ariz. 424, 427, ¶ 7 (App. 2014).

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