## Facts

- George Saber, a Massachusetts resident, bought a used 1985 Chevrolet Corvette from Dan Angelone Chevrolet, Inc., a Rhode Island dealer, on February 7, 1990, for $14,900, and also purchased an extended warranty.
- From March 1990 through April 1992, Saber experienced repeated mechanical problems and returned the car to the dealer for service.
- A title search revealed discrepancies between paperwork (black, manual transmission) and the car sold to Saber (red, automatic).
- A Massachusetts State Police inspection found identification irregularities, including a blistered/painted-over VIN plate, mismatched derivative numbers on major components, a missing VIN sticker, and a part inconsistent with the model year.
- Based on suspected theft indicators, Massachusetts authorities impounded the vehicle and opened an investigation.
- The investigation later concluded the car and parts were not stolen; it had been a fire-damaged “total loss” rebuilt from multiple vehicles and repainted, information not disclosed to Saber before purchase.
- The vehicle remained impounded through trial, depriving Saber of possession and use.

## Issues

1. Whether the dealer breached the UCC warranty of title by selling a vehicle whose apparent identification irregularities led to law-enforcement impoundment that substantially disturbed the buyer’s possession, even though the vehicle was later found not to be stolen.
2. Whether the buyer provided sufficient notice of the alleged breach to the seller under the UCC.
3. Whether the trial justice properly ruled, as a matter of law, that the warranty of title was breached and properly admitted evidence concerning the car’s condition and repair history.

## Decision

- The Rhode Island Supreme Court denied and dismissed the dealer’s appeal and affirmed judgment for Saber.
- The court upheld the trial justice’s ruling that the dealer breached the warranty of title as a matter of law.
- The court upheld the jury’s finding that Saber gave adequate notice of breach.
- The court found no reversible error in the challenged evidentiary rulings.
- The court affirmed the $14,900 damages award (purchase price).

## Legal Principles

- Under UCC § 2-312, the warranty of title protects not only formal title but also the buyer’s right to quiet possession.
- A substantial disturbance of possession caused by government action grounded in apparent title/identity irregularities can constitute breach of the warranty of title, even if a later investigation determines no theft and no superior titleholder emerges.
- Subsequent confirmation that the goods are not stolen does not necessarily cure a breach when the buyer has been deprived of possession and use due to defects or irregularities traceable to the condition of the goods at sale.
- Adequacy of UCC notice is generally a fact question; a jury’s notice finding will stand where supported by evidence that the seller was reasonably informed of the asserted breach.
- Trial courts may decide breach as a matter of law when material facts establishing disturbance of possession are undisputed; evidentiary rulings are reviewed for abuse of discretion.

## Conclusion

The court held that the dealer breached the UCC warranty of title because police impoundment based on serious identification irregularities substantially interfered with the buyer’s quiet possession, and it affirmed the jury’s findings on notice and damages awarding the purchase price.


Saber v. Dan Angelone Chevrolet, Inc., 811 A.2d 644 (R.I. 2002)