## Facts

- G. W. Haight bought a used Jeep Grand Cherokee from Dale’s Used Cars, Inc. (Dale’s).
- At the time of sale, the Jeep was still covered by the manufacturer’s new-car warranty.
- Soon after the purchase, a Jeep dealer informed both Haight and Dale’s that the Jeep had previously been in a collision.
- The Jeep dealer estimated the cost to repair the collision-related condition at about $2,800, which was about 10 percent of the Jeep’s purchase price.
- After learning of the collision history and repair estimate, Haight attempted to revoke his acceptance of the Jeep and demanded return of the purchase money.
- Dale’s refused to refund the purchase price.
- Haight sued under Idaho’s Uniform Commercial Code (UCC), seeking revocation of acceptance and return of the price.
- At the bench trial, the parties presented conflicting evidence about whether Haight’s decision to buy the Jeep turned on safety-related expectations.
- The trial court found that the estimated $2,800 cost to address any safety-related concerns was not enough to substantially impair the Jeep’s value to Haight.
- The trial court concluded that Haight had no right to revoke acceptance, entered judgment for Dale’s, and awarded Dale’s attorney’s fees.
- Haight appealed to the Idaho Court of Appeals, challenging the revocation ruling and also arguing that federal warranty law barred Dale’s disclaimer of implied warranties.

## Issues

1. Did the Jeep’s undisclosed prior collision damage—repairable for about $2,800 (about 10 percent of the purchase price)—substantially impair the Jeep’s value to Haight so that he could revoke acceptance under Idaho’s UCC?
2. Did the Magnuson-Moss Warranty Act bar Dale’s from disclaiming implied warranties because the Jeep remained subject to the manufacturer’s new-car warranty?

## Decision

- The Idaho Court of Appeals affirmed the judgment for Dale’s.
- The court held that the trial court did not err in finding no substantial impairment of value to Haight; therefore, Haight’s revocation of acceptance was ineffective.
- The court rejected Haight’s federal warranty argument, holding that he failed to show Dale’s disclaimer of implied warranties was prohibited by the Magnuson-Moss Warranty Act merely because a manufacturer’s warranty still existed.
- The court declined to address additional assignments of error that were inadequately supported by argument and legal authority.
- The court left intact the trial court’s award of attorney’s fees to Dale’s as the prevailing party.

## Legal Principles

- Under Idaho’s version of U.C.C. § 2-608, a buyer may revoke acceptance only if a nonconformity substantially impairs the value of the goods to that buyer and the statutory timing/notice conditions are met.
- “Substantial impairment” is determined from the value of the goods to the particular buyer, but the trial court’s impairment finding is a fact determination that appellate courts generally review deferentially.
- A repairable defect with a relatively modest repair cost compared to the purchase price may support a finding of no substantial impairment, especially where warranty coverage reduces the buyer’s repair risk.
- The Magnuson-Moss Warranty Act limits implied-warranty disclaimers in certain circumstances (such as when the seller gives a written warranty), but the continued existence of a separate manufacturer’s warranty does not, by itself, prevent a used-car dealer from disclaiming implied warranties.
- On appeal, issues not supported with developed argument and supporting authority may be treated as waived and not decided.

## Conclusion

The Idaho Court of Appeals affirmed judgment for the dealer because the trial court reasonably found that repairable, previously undisclosed collision damage costing about $2,800 did not substantially impair the used Jeep’s value to Haight, making his attempted UCC revocation ineffective, and because Haight did not show that the Magnuson-Moss Warranty Act invalidated the dealer’s implied-warranty disclaimer solely due to the manufacturer’s remaining warranty.


Haight v. Dale's Used Cars, 87 P.3d 962 (2003)