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Weber v. Warnke

8/28/2002

age title together with an application for a salvage certificate of title to the county treasurer of the county of their residence in this state within fifteen days after the date of assignment of the Nebraska certificate of title. Iowa Code § 321.52(4)(a). It is undisputed that they failed to do so. We conclude that the transfer of a salvage vehicle differs from the sale or transfer of a vehicle with a regular title in that acquiring an Iowa salvage certificate of title pursuant to section 321.52(4)(a) and related administrative rules is a condition precedent to any bona fide sale or transfer of a salvage vehicle for the purposes of section 321.493(2).


The Winkers conclude their argument on the single issue presented in their brief and discussed above by asserting that the trial court failed to address the "issue of consent," and that there was no evidence of consent in the record. To the contrary, the trial court concluded, in its ruling on Weber's motion for adjudication of law points, that Warnke was operating the Winkers' vehicle at the time of the accident with the Winkers' consent. Furthermore, to the extent that the Winkers contend that the trial court erred in resolving this issue against them in its ruling on the motion for adjudication of law points, we do not address this issue, as the Winkers raised it randomly, without elaboration or supportive authority. Soo Line R. Co. v. Iowa Dep't of Transp., 521 N.W.2d 685, 691 (Iowa 1994) (holding that a litigant's random mention of an issue, without elaboration or supportive authority, is not sufficient to raise the issue for our review). Finally, although not necessary to our decision, we note that in view of the Winkers' assertion Warnke was driving the vehicle as a result of their sale of it to him there can be no genuine issue as to whether he was driving it with their consent.


IV. CONCLUSION.


We affirm the trial court's challenged ruling on Weber's motion for adjudication of a law point.


AFFIRMED.






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