Sanchez v. Rains Precision Motorsports, Inc.

2025 COA 40
CourtColorado Court of Appeals
DecidedApril 17, 2025
Docket24CA0725
StatusPublished

This text of 2025 COA 40 (Sanchez v. Rains Precision Motorsports, Inc.) 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
Sanchez v. Rains Precision Motorsports, Inc., 2025 COA 40 (Colo. Ct. App. 2025).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY April 17, 2025

2025COA40

No. 24CA0725, Sanchez v. Rains Precision Motorsports, Inc. — Vehicles and Traffic — Motor Vehicle Repair Act of 1977 — Repairs on a Motor Vehicle

A division of the court of appeals addresses, for the first time

in a published decision by a Colorado appellate court, issues

pertaining to the construction and application of Colorado’s Motor

Vehicle Repair Act of 1977, §§ 42-9-101 to -113, C.R.S. 2024. COLORADO COURT OF APPEALS 2025COA40

Court of Appeals No. 24CA0725 Arapahoe County District Court No. 22CV31708 Honorable Thomas W. Henderson, Judge

Juan Sanchez,

Plaintiff-Appellee,

v.

Rains Precision Motorsports, Inc., d/b/a Rains Precision Motorsports L.L.C.,

Defendant-Appellant.

JUDGMENT AFFIRMED AND CASE REMANDED WITH DIRECTIONS

Division I Opinion by JUDGE J. JONES Brown and Yun, JJ., concur

Announced April 17, 2025

S&D Law, Angela D. DeVine, Denver, Colorado, for Plaintiff-Appellee

Earl & Earl, PLLC, Collin J. Earl, Ryan T. Earl, Brian E. Hefner, Colorado Springs, Colorado, for Defendant-Appellant ¶1 Defendant, Rains Precision Motorsports, Inc. (RPM), appeals

the district court’s judgment in favor of plaintiff, Juan Sanchez,

following a jury trial on Sanchez’s claims for violations of Colorado’s

Motor Vehicle Repair Act of 1977 (CMVRA), §§ 42-9-101 to -113,

C.R.S. 2024, and negligence. We affirm.1 In doing so, we address

for the first time in a published decision by a Colorado appellate

court issues pertaining to the construction and application of the

CMVRA.

1 To the extent RPM attempts to appeal the district court’s order

denying its motion for summary judgment, we can’t review that order because, under circumstances like those in this case, such an order isn’t appealable. Feiger, Collison & Killmer v. Jones, 926 P.2d 1244, 1249-50 (Colo. 1996).

1 I. Background

¶2 Sanchez owned a 2003 Chevy Silverado truck. In August

2021, Sanchez replaced the truck’s camshaft.2 But soon after, the

truck’s engine started to make an unusual noise. Sanchez tried to

fix the problem on his own but couldn’t. He brought his truck to

RPM for repairs and replacements of parts (including the muffler,

which had fallen off) the following month. Sanchez supplied some

of the replacement parts himself. RPM estimated that the repairs

A camshaft is a rod which rotates and slides against a piece of machinery in order to turn rotational motion into linear motion. This change of motion is accomplished by the camshaft moving further and closer from the axis of rotation as the camshaft is pushed by the machinery. These moving pieces of the shaft are the cams. . . . A camshaft on an internal combustion heat engine is a device that controls both the input of fuel and the expulsion of exhaust fumes. It consists of several radial cams, each displacing intake or exhaust valves. This camshaft is connected to the crankshaft via belt, chain or gears. This ensures consistent timing of the valves in relation to the motion of the pistons.

Energy Education, Camshaft, https://perma.cc/X5XZ-PACV; see also Cambridge Dictionary, https://perma.cc/PV7Z-X9W9 (A camshaft is “a device that causes the valves of an engine to open or close at the correct time.”).

2 and replacements would cost $6,000, which Sanchez agreed to pay.

(Sanchez paid $1,040 up front.)

¶3 Several months passed without any word from RPM on the

status of Sanchez’s truck. In late December 2021, RPM called

Sanchez to tell him that the truck was ready and that the repairs

would cost about $12,040, which was approximately $6,000 more

than the previously agreed-to amount. When Sanchez went to

retrieve his truck the next day, however, it wasn’t ready because the

repairs to the exhaust system hadn’t been performed. Nonetheless,

he agreed to pay the $12,040 and allowed RPM to finish the repairs.

¶4 In March 2022, RPM told Sanchez that it had completed the

repairs, so Sanchez picked up his truck. But during the drive

home, the truck started to make another unusual noise, this time

from the torque converter, which RPM had installed. RPM told

Sanchez he should bring the truck back to be checked. Sanchez

brought the truck back, and RPM thereafter retained possession of

it until March 29, 2022 — when someone stole the truck from

RPM’s lot.

¶5 Sanchez recovered his truck in August 2022. One month

later, he filed suit against RPM. His complaint alleged that RPM

3 violated section 42-9-104(2)(a)(I), C.R.S. 2024, of the CMVRA

(requiring a repair facility to provide the customer with an

estimated date of completion), and section 42-9-105(1), C.R.S.

2024, of the CMVRA (requiring a repair facility to gain the

customer’s consent before conducting work for which it will charge

the customer that isn’t included in the original estimate). The

complaint also alleged that RPM was negligent under a bailment

theory, alleging that it failed to exercise reasonable care to protect

Sanchez’s truck from theft. Sanchez sought damages of $7,611 on

his CMVRA claim and $13,000 (the alleged value of his vehicle) on

his negligence claim.

¶6 RPM filed a motion for summary judgment, which the district

court denied. After a two-day trial, the jury determined 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. See § 42-9-113, C.R.S. 2024.

¶7 RPM filed a motion for judgment notwithstanding the verdict

(JNOV), arguing that the CMVRA’s protections for customers didn’t

apply to RPM’s work on Sanchez’s truck and that insufficient

4 evidence supported the jury’s negligence verdict. The district court

denied RPM’s motion.

II. Discussion

¶8 RPM contends that the district court erred by denying its

motion for JNOV because (1) the CMVRA doesn’t apply to RPM’s

work on Sanchez’s truck and (2) the jury’s negligence verdict isn’t

supported by sufficient evidence. We address, and reject, both

contentions in turn.

A. Applicability of the CMVRA

¶9 RPM contends that the CMVRA doesn’t apply to the work it did

on Sanchez’s truck because (1) that work constituted, in RPM’s

view, “modifications or enhancements to the performance” of the

truck, which aren’t covered by the CMVRA; and (2) parts it installed

on the truck — at Sanchez’s behest — rendered the truck “not legal

for street use,” meaning the truck was not “intended primarily for

use and operation on the public highways,” as required by section

42-9-102(2)(a), C.R.S. 2024, of the CMVRA.

1. Standard of Review

¶ 10 We review de novo the district court’s denial of RPM’s motion

for JNOV. Boulders at Escalante LLC v. Otten Johnson Robinson

5 Neff & Ragonetti PC, 2015 COA 85, ¶ 19. The facts relevant to

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