Owens v. Samkle Automotive Inc.

Glendale Owens (plaintiff) bought a used car from a Mazda dealership owned by Samkle Automotive (defendant), which never provided the original title as the federal Odometer Act requires and used noncompliant, non-official sale forms lacking mandatory disclosures; Owens later learned the car had previously been a short-term Hertz rental car, and alleged she never would have purchased it had she known, suing under the Odometer Act for intentional fraud in withholding the title. The district court dismissed her complaint, holding recovery required the defendant's fraudulent intent to specifically relate to the car's mileage, and Owens appealed.