McCurdy v. Copart

CourtColorado Court of Appeals
DecidedMay 29, 2025
Docket24CA0954
StatusUnpublished

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

Bluebook
McCurdy v. Copart, (Colo. Ct. App. 2025).

Opinion

24CA0954 McCurdy v Copart 05-29-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 24CA0954 Adams County District Court No. 21CV31133 Honorable Sarah E. Stout, Judge

Courtney McCurdy,

Plaintiff-Appellee,

v.

Copart, Inc.,

Defendant-Appellant.

JUDGMENT AFFIRMED IN PART AND REVERSED IN PART, AND CASE REMANDED WITH DIRECTIONS

Division VI Opinion by JUDGE WELLING Kuhn and Schutz, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced May 29, 2025

Ramos Law, Matthew R. Osborne, Northglenn, Colorado; Jennifer Mrachek, Golden, Colorado, for Plaintiff-Appellee

Brown Gren Abraham & McCracken, LLC, Joshua D. Brown, Andrew J. Royer, Denver, Colorado, for Defendant-Appellant ¶1 Defendant, Copart, Inc., appeals the judgment in favor of

plaintiff, Courtney McCurdy, for fraudulent nondisclosure or

concealment1 and violating the Colorado Consumer Protection Act

(CCPA). We affirm in part, reverse in part, and remand to the trial

court for further proceedings.

I. Background

A. McCurdy’s Injury

¶2 McCurdy’s claims in this case stem from her purchase of a

trailer that had previously been damaged in an accident in

Michigan. After the accident, Auto Club Insurance Association

(AAA)2 declared the trailer a “total loss,” paid out an insurance

claim to the owner for the full value of the of the trailer, and took

possession of it.

1 As a shorthand, throughout this opinion, we refer to this claim as

“fraudulent nondisclosure.” 2 According to the second amended complaint, Auto Club Insurance

Association (ACIA) sells insurance in Michigan, and CSAA General Insurance Company (CSAA) is a sister company of ACIA that sells insurance policies in Colorado. ACIA and CSAA both “fall under the AAA umbrella of companies” and “use the AAA logo on communications to third parties.” Based on this and because the distinction between these two entities isn’t material to this appeal, we refer to them both as AAA throughout this opinion.

1 ¶3 Copart is an auction marketplace that remarkets and consigns

vehicles. Copart has an agreement with AAA giving it the right to

sell “totaled out” vehicles for AAA. Depending on the contract,

Copart also handles titling for the seller. As part of its contract with

AAA, Copart agreed to title the trailer, but Copart never owned the

trailer.

¶4 After AAA took possession of the trailer, it told Copart to

“brand [the trailer] per state guidelines.” Then, AAA sold the trailer

through a Copart auction to Lakewood RV, a company located in

Missouri. The auction disclosed “primary damage to the top roof

and secondary minor dent damage.”

¶5 After receiving the trailer, Lakewood RV inspected it and

decided to resell the trailer through a Copart auction. This time the

auction listed the trailer as having damage to the “top roof.” The

winning bidder at the auction was Mac Scooters. But Mac Scooters

quickly had the transaction reversed complaining of “unlisted

damage of the undercarriage [or] frame making it unable to be

[pulled].”

¶6 The trailer was then sold again through another Copart

auction to APB Motors, a company located in Colorado. This time

2 Copart disclosed “top roof” and “frame damage.” APB Motors

brought the trailer to Colorado.

¶7 After receiving the trailer, APB Motors inspected it and found

“too much damage that was not visible initially,” so it consigned or

sold the trailer in another Copart auction to RV Trailers of America,

a company located in Colorado. The consignment agreement and

auction listed frame damage. But RV Trailers of America made the

decision to again sell the trailer through yet another Copart

auction. This time Scarpa Motors, a company located in Colorado,

was the winning bidder. The auction at which Scarpa Motors

acquired the trailer listed it only as having “minor dents and

scratches.”

¶8 Each time the trailer was sold with a clean title and “as-is,” “as

where is,” without any warranties. Scarpa eventually sold the

trailer to McCurdy. Copart wasn’t directly involved in the sale of

the trailer to McCurdy.

¶9 When McCurdy and her husband (collectively, the McCurdys),

first used the trailer, they noticed that the “tires were rubbing on

the underside of the wheel well.” The McCurdys took the trailer

back to Scarpa and agreed with Scarpa to split the cost of repairs.

3 ¶ 10 After Scarpa made repairs to the trailer, the McCurdys took

the trailer out again, this time over Monarch Pass. McCurdy’s

husband was driving, and he later testified that, at the bottom of

the pass, “it felt like the brakes were either hot or locked up or

something wasn’t right.” McCurdy’s husband couldn’t find a place

to pull over, so he had to keep driving and noticed that “the tire

started smoking.” Eventually, he found a place to pull over on the

side of a two-lane stretch of Highway 50 that was “about [thirty]

miles from Monarch Pass.” McCurdy’s husband testified that where

he pulled off “was actually an embankment that sloped down so the

trailer was leaning to the side.” According to McCurdy’s husband,

he saw that “the tires from the axles were rubbing together and

that’s what was causing the smoke.” The McCurdys didn’t have cell

phone service where they had stopped, so they had to keep driving

until they reached a gas station to call for a tow. The McCurdys

also contacted their insurance company, AAA, to file a claim, but

the claim was never paid because “the trailer was already totaled.”

The McCurdys placed the trailer in storage and didn’t drive it again

or repair it.

4 B. Procedural History

¶ 11 McCurdy initially filed suit against Scarpa, APB Motors, and

RV Trailers of America. She then amended her complaint to include

Copart and AAA. APB Motors wasn’t a listed defendant in the first

amended complaint and the claims against it were eventually

dismissed. McCurdy then filed a second amended complaint

bringing claims against Copart for (1) fraudulent nondisclosure for

auctioning the trailer with a clean title and misrepresenting the

frame damage and (2) violations of the CCPA for failing to apply for

a salvage title and misrepresenting the damages to the trailer. The

claims against Scarpa and AAA were eventually settled.

¶ 12 RV Trailers of America and Copart filed separate motions for

summary judgment. In its motion, Copart requested the entry of

judgment on both the fraudulent nondisclosure and CCPA claims.

In an order addressing both motions, the court granted summary

judgment in favor of RV Trailers of America, dismissing the claims

against it, and partially granted summary judgment in favor of

Copart, finding that McCurdy couldn’t prevail on a fraudulent

nondisclosure claim for the frame damage against Copart.

5 ¶ 13 The surviving claims against Copart proceeded to trial. After a

four-day trial, the jury found in favor of McCurdy and against

Copart on both the fraudulent nondisclosure and CCPA claims.

The jury awarded her a total of $700,000 in economic and

noneconomic damages. The jury also found by clear and

convincing evidence that Copart had acted in bad faith.

¶ 14 After trial, McCurdy requested the court treble the awarded

damages because the jury had found that Copart violated the CCPA

and acted in bad faith.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Karg v. Mitchek
983 P.2d 21 (Colorado Court of Appeals, 1998)
Mallon Oil Co. v. Bowen/Edwards Associates, Inc.
965 P.2d 105 (Supreme Court of Colorado, 1998)
Bennett v. BD. OF TR. FOR U. OF N. COLO.
782 P.2d 1214 (Colorado Court of Appeals, 1989)
Williams v. Chrysler Insurance Co.
928 P.2d 1375 (Colorado Court of Appeals, 1996)
Schnell v. Gustafson
638 P.2d 850 (Colorado Court of Appeals, 1981)
Burgess v. Mid-Century Insurance Co.
841 P.2d 325 (Colorado Court of Appeals, 1992)
Harvey v. Harvey
841 P.2d 375 (Colorado Court of Appeals, 1992)
Martinez v. Lewis
969 P.2d 213 (Supreme Court of Colorado, 1998)
Hall v. Walter
969 P.2d 224 (Supreme Court of Colorado, 1998)
Zolman v. Pinnacol Assurance
261 P.3d 490 (Colorado Court of Appeals, 2011)
Anderson v. Pursell
244 P.3d 1188 (Supreme Court of Colorado, 2011)
Colorado Coffee Bean, LLC v. Peaberry Coffee Inc.
251 P.3d 9 (Colorado Court of Appeals, 2010)
Rhino Linings USA, Inc. v. Rocky Mountain Rhino Lining, Inc.
62 P.3d 142 (Supreme Court of Colorado, 2003)
Harris Group, Inc. v. Robinson
209 P.3d 1188 (Colorado Court of Appeals, 2009)
Palmer v. Diaz
214 P.3d 546 (Colorado Court of Appeals, 2009)
Anson v. Trujillo
56 P.3d 114 (Colorado Court of Appeals, 2002)
Jagow v. E-470 Public Highway Authority
49 P.3d 1151 (Supreme Court of Colorado, 2002)
Clough v. Williams Production RMT Co.
179 P.3d 32 (Colorado Court of Appeals, 2007)
East Meadows Co. v. Greeley Irrigation Co.
66 P.3d 214 (Colorado Court of Appeals, 2003)
Rhino Fund, LLLP v. Hutchins
215 P.3d 1186 (Colorado Court of Appeals, 2009)

Cite This Page — Counsel Stack

Bluebook (online)
McCurdy v. Copart, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mccurdy-v-copart-coloctapp-2025.