Chrysler
Credit Corporation v. Jimmy McKinney, et al.
Supreme Court of Alabama
1984 Ala. LEXIS 4246
June 22, 1984
Defendant Chrysler Credit Corporation appeals from a judgment entered
against it and in favor of the plaintiffs in the amount of $20,000. We
affirm.
In July 1980, Jimmy McKinney bought a Dodge Mirada from Countywide
Dodge for his wife's use. He negotiated and executed on behalf of
McKinney Ceramic Tile Co., Inc., of which he was president and majority
stockholder, a retail installment contract financing the automobile
with Chrysler Credit Corporation. McKinney made only two payments
pursuant to this agreement, because Countywide Doge failed to repair
the car to his satisfaction.
McKinney returned the car to Countywide Dodge on numerous occasions for
repairs. The dealership successfully repaired most of the defects, but
never succeeded in repairing a leak in the roof of the automobile. This
leak was so bad that at times, after a rainshower, two inches of water
was left standing in the front floor. Because of this repeated leaking,
the car's interior had an offensive odor, and the leather interior was
damaged.
Mr. McKinney visited the dealership time after time and, at one point
in September, explained the problem to the owner of Countywide Dodge,
who assured him it would be repaired. It was not. He then wrote letters
to the dealership, Chrysler Corporation, and Chrysler Credit
Corporation, notifying them that he would make no more payments on the
vehicle until the leak was repaired. He received no responses to these
letters. Chrysler Credit later telephoned him about his failure to make
the payments on the vehicle. Once again, he discussed the leak in the
roof and was assured that it would be repaired. Soon thereafter, James
Smith, a repossession agent of Chrysler Credit, contacted Mrs. McKinney
about the car and the McKinneys' failure to make the payments on the
note. Mrs. McKinney met Smith at a restaurant to discuss the matter.
After a conversation, wherein Mrs. McKinney detailed to Smith the
problem with the car, she and Smith reached an agreement. Mrs. McKinney
testified as follows concerning the agreement:
"He [Smith] told me that everything was
fine, that all he had to do was to get me to take the car in to the lot
and it would be fixed. You know, they would fix the leak in it. And, if
they fixed the leak in it, then we would bring up the payment, which I
agreed to."
Mrs. McKinney called their attorney from the restaurant. He spoke with
Smith and confirmed the agreement not to repossess the car unless and
until the McKinneys failed to bring the payments up to date following
the repair of the vehicle's roof.
Mrs. McKinney and Smith then left the restaurant and drove to the
dealership, where Mrs. McKinney surrendered the automobile to the
dealership for repairs. The owner of the dealership confirmed the
agreement to catch up the past due payments when the car was repaired.
A few days later, Chrysler Credit sent repossession notices to the
McKinneys, advising them that the automobile had been repossessed and
would be sold within five days after the receipt of those notices. The
attorney for the McKinneys corresponded with Chrysler Credit, informing
them of the agreement that repossession would not occur unless the
repairs were made and the payments were not then brought up to date.
Chrysler Credit did not respond to this letter.
The day after the repossession took place, Chrysler Credit called upon
Countywide Dodge to pay off the McKinney account, pursuant to its
recourse agreement, which it did.
Following these events, Countywide again made numerous attempts to
repair the leaking roof in the car. Several times Mr. McKinney went in
to the dealership and, each time, the roof leaked when tested. Later,
Mr. McKinney was told to remove his personal belongings from the
vehicle because it was no longer his car and was being sold. Thereupon
Mr. McKinney filed suit against Chrysler Credit, Chrysler Corporation,
and Countywide Dodge.
The trial court granted Countywide's motion for directed verdict at the
close of the plaintiffs' case. The jury returned a verdict against
Chrysler Corporation and in favor of the plaintiffs for breach of
warranty. That verdict is not an issue in this appeal. The jury also
returned a verdict against Chrysler Credit Corporation for $20,000.00
on a conversion claim.
Only Chrysler Credit appealed. It argues that a conversion of the
plaintiffs' vehicle never took place because the McKinneys were in
default, and Chrysler Credit, acting within its rights under §
7-9-503, Ala. Code 1975, was entitled to possession. The right under
contract to repossess an automobile upon default has been recognized
consistently since the adoption of § 7-9-503. That section reads:
§
7-9-503. Secured party's right
to take possession after default
"Unless otherwise agreed a secured
party has on default the right to take possession of the collateral. In
taking possession a secured party may proceed without judicial process
if this can be done without breach of the peace or may proceed by
action. If the security agreement so provides the secured party may
require the debtor to assemble the collateral and make it available to
the secured party at a place to be designated by the secured party
which is reasonably convenient to both parties. Without removal a
secured party may render equipment unusable, and may dispose of
collateral on the debtor's premises under section 7-9-504.
Section 7-9-503 gives the secured party the right to possession upon
default, but it does not authorize repossession by trick or fraud.
The evidence in this case would permit a jury to find that Mrs.
McKinney was tricked into surrendering the automobile to the
repossession agent of Chrysler Credit and the Dodge dealer. The
evidence also supports a finding that Chrysler Credit fraudulently led
Mrs. McKinney to believe that the car would not be repossessed unless
the McKinneys failed to make the necessary payments after the car was
repaired. The jury could find that Chrysler Credit breached the
agreement and two days later sent the McKinneys repossession notices.
The facts here are very similar to those considered in Ford Motor
Credit Company v. Byrd, 351 So. 2d 557 (Ala. 1977), where the Court
held that a repossession by trick, artifice, or fraud is wrongful and
will support an action for conversion of the chattel.
In Byrd, the owner/debtor was persuaded to take his car to the
dealership in order to establish whether he was in fact in default.
Once the car was on the dealer's lot, and while the owner was inside
reviewing his account, the car was taken and locked in a storage area,
without the knowledge of the owner.
Self-help repossession is not permitted in all circumstances. As this
Court set out in Byrd:
"We cannot interpret § 9-503 to
permit obtaining possession through trick, without
knowledge on the part of the debtor. To interpret § 9-503 to allow
repossession in these circumstances would encourage practices abhorrent
to society: fraud, trickery, chicanery, and subterfuge, as alternatives
to employment of judicial processes that foster the concept of ours
being a government of laws and not of men."
As Byrd held, a repossession by artifice, trick, or fraud will support
an action for conversion. The evidence clearly supports the jury's
finding of wrongful repossession and conversion.
The plaintiffs properly withheld payment on the automobile until all
the defects which impaired the value of the vehicle to them were
repaired. Certainly, a substantial defect existed in the McKinneys'
automobile and, until that defect was cured or repaired, the McKinneys
had the right under their installment contract to withhold payment on
the vehicle. That contract was assigned to Chrysler Credit and
contained a provision which read: "Any holder of this consumer credit
contract is subject to all claims and defenses which the debtor could
assert against the seller of goods or services obtained pursuant hereto
or with the proceeds hereof." Countywide Dodge had failed to honor its
commitment to repair the vehicle, thereby subjecting Chrysler Credit to
the McKinneys' right to withhold payment.