CJ-2026-295 - Nathan Andes v. Ralph V. Payne

What's This Case About?

Let’s get one thing straight: this is not just a story about a used truck. This is a story about trust, betrayal, and the wild, unspoken rule of Facebook Marketplace: you don’t bring a checkbook to a cash-and-lie fight. Nathan Andes, a man from Kansas with dreams of smooth highway hauls and maybe a little off-roading on the weekend, ended up with something far less glamorous — a $18,000 paperweight with a lien the size of a tornado siren. That’s right: he bought a Ford F250, paid in cold, hard cash and certified checks (yes, plural), and discovered too late that the guy selling it had basically pawned the truck to the bank and forgot to mention it. Not just forgot — lied, repeatedly, like a con artist with a cowboy hat and a Yukon zip code.

So who are these players in this Oklahoma drama? On one side, we’ve got Nathan Andes — regular guy, out-of-state buyer, probably Googled “how to buy a used truck safely” the night before but missed the part about getting the title before you drive it across state lines. On the other, we have Ralph V. Payne, a Canadian County resident whose idea of “seller’s remorse” apparently involves keeping the money and the debt. The two weren’t friends. No family ties. No long-standing feud. Just a Facebook listing, a handshake deal, and a whole lot of bad decisions. Nathan saw a 2014 Ford F250 Platinum — a shiny, rugged beast with enough torque to tow a small house — and thought, This is the one. Ralph saw Nathan coming and, allegedly, saw dollar signs. Big ones. Eighteen thousand of them, to be exact.

Here’s how it all went sideways. In July 2025 — yes, the future, folks, we’re living in it — Nathan spotted the truck online. He messaged Ralph. They chatted. Everything seemed legit. Ralph said the truck was running great, no issues, title in hand. So Nathan, being the responsible adult he is, packed up and drove all the way from Kansas to Yukon, Oklahoma — a trip that, depending on traffic and Dairy Queen stops, is about a four-hour haul. He shows up on July 17th, meets Ralph, inspects the truck, and — bam — decides to buy it. No test drive drama, no last-minute cold feet. He pulls out $6,000 in cash and a $12,000 check. Total: $18,000. And get this — they even signed a Bill of Sale. It’s like a movie. A very, very dumb movie.

But then, right before the keys change hands, Ralph casually drops the bomb: Oh yeah, there’s a lien on the title. Cue record scratch. Nathan, standing there with his wallet wide open, is now in a classic “sunk cost” nightmare. He’s driven hours. He’s got cash in hand. The truck’s right there, purring like a contented grizzly. And Ralph says, “Don’t worry, buddy — I’ll pay it off by next Friday. Promise.” So Nathan, against every instinct screaming run, decides to roll the dice. He takes the truck home, lien and all, banking on Ralph being a man of his word.

Spoiler: he is not.

July 25th rolls around — the magic Friday. Nathan checks in. “Hey, lien cleared yet?” Ralph says, “Soon. Real soon.” Then radio silence. Nathan starts calling. Texting. Begging. Every time, same answer: “It’s coming.” But the lien? Still there. The title? Still murky. And worst of all — Nathan can’t even insure the truck. Try getting Geico to cover a vehicle you don’t legally own. It’s like trying to adopt a dog that’s still technically someone else’s emotional support animal.

Now, let’s talk about why this is a lawsuit and not just a sad post on Reddit. Nathan’s lawyers — a whole team of them, because apparently this is serious business — filed a petition with enough legal firepower to sink a battleship. The claims? Breach of contract (you promised to clear the lien, you didn’t). Breach of warranty (the law says when you sell a car, you’re guaranteeing you actually own it — surprise, Ralph didn’t). Violations of the Oklahoma Uniform Commercial Code (yes, that’s a real thing, and yes, it applies to trucks). And then, the spicy stuff: fraud, misrepresentation, and fraud in the inducement. In plain English: you lied to me, I believed you, and now I’m screwed.

The kicker? Nathan wants his $18,000 back — either that, or the lien paid off so he can actually own the truck. He’s also asking for punitive damages, which is the legal equivalent of saying, “I don’t just want my money — I want you to hurt for doing this.” Is $18,000 a lot for a used F250? Honestly? For a 2014 Platinum with decent miles, it’s fair. But here’s the thing — Nathan didn’t buy a truck. He bought a legal headache. He’s stuck with a vehicle he can’t register, can’t insure, and definitely can’t sell. So that $18,000? It’s not just money. It’s a prison sentence disguised as a pickup.

And let’s address the elephant in the room: why didn’t Nathan just walk away? Why not say, “Nope, lien? Hard pass,” and go home? Well, he already drove four hours. He already handed over cash. And Ralph didn’t say, “There’s a lien and I have no intention of paying it.” He said, “I’ll fix it.” That’s the difference between a sketchy sale and a scam. One is unfortunate. The other is intentional. And Nathan’s filing suggests this wasn’t just negligence — it was calculated. The guy took the money, allegedly spent it (or moved it, or hid it — the petition says “commingled,” which sounds like a financial crime and a smoothie at the same time), and left Nathan holding a truck that’s basically a very expensive lawn ornament.

Now, our take? Look, we’ve covered lawsuits over stolen chickens, feuding garden gnomes, and a woman who sued her neighbor for “emotional distress” caused by loud duck calls. But this one? This is next level. The sheer audacity of selling a truck you don’t fully own — and then promising to fix it while quietly doing nothing — is like a villain origin story. And the fact that Nathan drove all the way from Kansas, paid in cash and check, and still got played? That’s not just bad luck. That’s a cautionary tale for every person who’s ever bought anything off Facebook.

But here’s what we’re really rooting for: transparency. Not just in car sales, but in life. If you’ve got a lien, say so. If you’re broke, say so. But don’t take $18,000 from a guy who just wanted a reliable truck and then ghost him like a bad Tinder date. And Nathan? We salute you. You may have lost the battle, but you’ve inspired a generation of used car buyers to get the title first, drive it later.

This case is still pending. No trial date yet. But if it goes to jury, we’re calling it now: this is going to be the most dramatic Canadian County has seen since the Great Tractor Parade of ‘09. And when the verdict drops? We’ll be here — popcorn ready, legal jargon translator on standby, and deeply, deeply invested in the fate of one very unfortunate Ford F250.

Case Overview

$18,000 Demand Jury Trial Petition

Jurisdiction

District Court, Oklahoma

Filing Attorney

LES BENNETT JR.

BENNETT VERNIER, PLLC.

Relief Sought

$18,000 Monetary

$1 Punitive

Plaintiffs

Nathan Andes individual
Rep: LES BENNETT JR., #32352, TRAVIS VERNIER, #35253, AUSTIN VERNIER, #35759, AUSTIN PROCTOR, #31418

Defendants

Ralph V. Payne individual

Claims

#	Cause of Action	Description
1	Breach of Contract, Breach of Warranty, Rescission, and Violations of the Oklahoma Uniform Commercial Code	Plaintiff purchased a Ford F250 from Defendant, but Defendant failed to remove a lien on the title.

Petition Text

1,384 words

IN THE DISTRICT COURT OF CANADIAN COUNTY STATE OF OKLAHOMA Nathan Andes, an individual Plaintiff, vs. Ralph V. Payne, an individual Defendant. Case No. PAUL HESSE PETITION COMES NOW the Plaintiff, Nathan Andes, by and through his attorneys of record, Les Bennett Jr., Travis Vernier, Austin Vernier, and Austin Proctor, all of BENNETT VERNIER, PLLC., for his Petition against the Defendant, Ralph V. Payne, and hereby states and alleges as follows: 1. That Plaintiff is an individual who resides in Kansas. 2. That Defendant is an individual whose last-known address is 837 Whitetail Trail Yukon, OK 73099, Canadian County. 3. That the amount in controversy is in excess of $10,000.00. 4. That therefore, jurisdiction and venue are both proper in Canadian County because Defendant resides in Canadian County, and because the acts and omissions giving rise to this action occurred in Canadian County. COMMON ALLEGATIONS 5. Plaintiff incorporates the allegations in the preceding paragraphs as though fully set forth herein. 6. On or about July 15th, 2025, Plaintiff was searching for a reliable and safe vehicle to purchase, and found a Facebook listing for a certain 2014 Ford F250 Platinum Vin: 1FT7W2BT6EEA53022 (the “Ford”). 7. Plaintiff communicated with Defendant regarding the Ford to ensure it remained available, and scheduled a date to travel down to Yukon, Oklahoma to view and potentially purchase the Ford. 8. On July 17th, 2025, Plaintiff traveled down to Yukon, Oklahoma and met Defendant. 9. Plaintiff decided to purchase the Ford, and paid $6,000.00 in cash, and $12,000 via check, for a total of $18,000.00, to Defendant. (See Exhibit “1" Bill of Sale) 10. Defendant never informed Plaintiff of the existence of any lien on the title to the Ford, until the time of sale, after Plaintiff had spent numerous hours traveling down rom Kansas to pick up the truck, and after the contract was signed. (See Exhibit “2" Vehicle Title) 11. However, Defendant assured Plaintiff that he would remove the lien by the following Friday, or July 25th, 2025. 12. Plaintiff, in reliance upon Defendant’s assurances, agreed to take the Ford and await the lien release. 13. On or about July 25th, 2025, Plaintiff inquired as to the lien release for the Ford, and Defendant assured he would be removing it soon. 14. Plaintiff has made numerous requests to have the lien removed, and Defendant has kept making hollow and dishonest assurances it would be removed. 15. However, Defendant has failed and refused to remove said lien, and as far as Plaintiff is aware, said lien remains unpaid and attached to the Ford. 16. Plaintiff is informed and believes that Defendant has absconded with Plaintiff’s funds, have deposited, transferred, commingled, and/or spent some or all of said funds, all without intending to remove said lien. 17. As a direct and proximate result of Defendant’s conduct, Plaintiff has been deprived of good, clean, and unencumbered title to the Ford, has been unable to insure the Ford, and has suffered damages. PLAINTIFF’S FIRST, SECOND, THIRD, AND FOURTH CAUSES OF ACTION BREACH OF CONTRACT, BREACH OF WARRANTY, RESCISSION, AND VIOLATIONS OF THE OKLAHOMA UNIFORM COMMERCIAL CODE 18. Plaintiff incorporates the allegations in the preceding paragraphs as though fully set forth herein. 19. Defendant breached the parties’ agreement by failing to satisfy and release the lien on the Ford as promised, and by failing to deliver good and unencumbered title. 20. That Defendant has breached its implied warranty of title under 12A O.S. § 2-312, which states that in a contract for sale, there is a warranty by the seller that “the title conveyed shall be good, and its transfer rightful.” 21. Defendant expressly represented and promised that he would use the sale proceeds to satisfy and release the existing lien on the Ford and thereby convey clear, transferable ownership to Plaintiff. 22. Plaintiff purchased the Ford relying on Defendant’s representations. 23. Defendant’s conduct breached the warranty of title under 12A O.S. § 2-312 and the express warranty under 12A O.S. § 2-313. 24. Defendant breached the agreement between the parties, whereby Defendant would pay off the lien on the Ford with the proceeds from the sale with Plaintiff. 25. Defendant failed to perform the parties’ agreement in good faith. 26. Plaintiff did not receive the benefit of his bargain. 27. Defendant’s conduct was intentional, and made with disregard to the rights of Plaintiff. 28. Plaintiff accepted the Ford on the reasonable assumption that Defendant would seasonably cure the title defect by paying off and releasing the lien. Plaintiff thereafter, within a reasonable time after discovering Defendant’s breach, provided notice of breach by repeatedly requesting and demanding that Defendant satisfy and remove the lien. Defendant failed and refused to do so. Accordingly, Plaintiff is entitled to recover damages for accepted goods in an amount exceeding Ten Thousand Dollars ($10,000.00), including the amount necessary to discharge the lien and obtain clear title, plus all incidental and consequential damages allowed by law. PLAINTIFF’S FIFTH CAUSE OF ACTION - UNJUST ENRICHMENT / RESTITUTION 29. Plaintiff incorporates the allegations in the preceding paragraphs as though fully set forth herein. 30. Defendant received the sales proceeds at the expense of Plaintiff. 31. Pled in the alternative, or as part of Plaintiff’s rescission theory, Defendant’s retention of the sale proceeds is unjust and inequitable because Defendant is not entitled to those proceeds absent the satisfaction of the lien on the Ford. 32. Equity and good conscience require that Defendant disgorge the proceeds and make restitution to Plaintiff. PLAINTIFF’S SIXTH, SEVENTH, AND EIGHTH CAUSES OF ACTION - FRAUD, MISREPRESENTATION, AND FRAUD IN THE INDUCEMENT 33. Plaintiff incorporates the allegations in the preceding paragraphs as though fully set forth herein. 34. Defendant made numerous false statements of material fact, or omitted material facts, in connection with the sale of the Ford, as well as his assurance that he was paying off the lien upon said Ford. 35. Defendant intended that Plaintiff rely on the statements and omissions in deciding to purchase the Ford and, thereafter, in refraining from immediately rescinding the transaction or taking legal action. 36. Plaintiff did rely on Defendant’s assurances, and continue to be damaged as a result. 37. Defendant’s fraudulent conduct directly and proximately caused damages to Plaintiff. 38. Plaintiff is entitled to recover both actual and punitive damages. PRAYER FOR RELIEF WHEREFORE, Plaintiff Nathan Andes prays for judgment against Defendant Ralph V. Payne as follows: A. On Plaintiff’s contract, warranty, and Uniform Commercial Code claims, for all actual damages in an amount in excess of Ten Thousand Dollars ($10,000.00), including but not limited to the amount necessary to satisfy and obtain release of the lien encumbering the 2014 Ford F250 Platinum, VIN 1FT7W2BT6EEA53022, together with all incidental and consequential damages allowed by law; B. Alternatively, on Plaintiff’s claim for rescission, for rescission of the sale transaction, restitution of the purchase price paid by Plaintiff in the amount of Eighteen Thousand Dollars ($18,000.00), together with such further restoration relief as may be just and proper; C. On Plaintiff’s fraud-based claims, for all actual and punitive damages as permitted by Oklahoma law; D. For prejudgment interest where allowed by law, and post-judgment interest as provided by law; E. For costs of this action, including Plaintiff’s reasonable attorney fees to the extent recoverable by statute, including but not limited to 12 O.S. § 939 with respect to Plaintiff’s express warranty claim under 12A O.S. § 2-313; and F. For such other and further legal or equitable relief as the Court deems just and proper. Respectfully submitted, [Signature] LES BENNETT JR., #32352 TRAVIS VERNIER, #35253 AUSTIN VERNIER, #35759 AUSTIN PROCTOR, #31418 6116 N.W. 63rd St. Warr Acres, OK 73132 P:(405) 346 -9800 E:[email protected] Attorneys for Plaintiff STATEMENT UNDER PENALTY OF PERJURY MADE PURSUANT TO OKLA. STAT. TIT. 12, § 426. I, Nathan Andes, Plaintiff in this matter, state under penalty of perjury under the laws of Oklahoma that the statements and allegations in the above and foregoing Petition are true and correct to my best knowledge, information, and belief, SO HELP ME GOD. Signed on this March 24, 2026, in the City of Winfield, County of Cowley, State of Kansas. Nathan Andes USED CAR BILL OF SALE This is to certify that on this day I, [REDACTED NAME], owner of the vehicle described below, hereby conveyed to [REDACTED NAME], the [REDACTED NAME] form below, which certifies the sale. Vehicle Information: VIN: JET1WZKT9ECS87927 Model: Ford Year: 2005 Mileage: 226,095 [REDACTED SIGNATURE] Date: [REDACTED DATE] THE OKLAHOMA STATE ARCHIVES STATE OF OKLAHOMA LAW DIVISION ARCHIVE DIVISION CASHIER'S RECEIPT NO. 20-314129 DATE: 03/17/2003 AMOUNT: $0.50