After a good discussion of the general principles governing how to determine if a statute grants a private cause of action for a statutory violation, this decision concludes that there is no private right of action for a violation of Bus. & Prof. Code 9884.9 which requires car repair facilities to provide the customer a written estimate and obtain written customer approval before beginning repairs on a car.  Nothing in the statute expressly grants the customer a cause of action for the repair facility’s violation of the section.  No other part of the Automotive Repair Act does either.  To the contrary, it provides instead for a comprehensive scheme of regulatory enforcement.

California Court of Appeal, Second District, Division 8 (Bigelow, P.J.); August 15, 2018 (modified September 11, 2018); 2018 Cal. App. Unpub. LEXIS 6277