What Is Curbstoning in Used Car Sales?
By Michael A. Klitzke, Auto Fraud & Lemon Law Attorney, Auto Law Firm, PC | Reviewed & updated June 2026
Learn how curbstoning scams work—and what you can do if you’ve been tricked by a fake private seller.
It Looked Like a Great Deal… Until It Was Too Late
The following is an illustrative example and does not describe an actual client or case.
When Marcus saw the ad online for a used car just down the street, it seemed perfect. Low mileage, clean title, priced thousands below market. The man selling it claimed it was his daughter’s old car. They met in a parking lot: handshake, cash, no red flags.
Two weeks later, the car broke down. Then came the real surprise: a branded salvage title, multiple past owners, and an illegal resale by someone with no dealer license.
Marcus had been scammed by curbstoning.
What Is Curbstoning in Car Sales?
Curbstoning refers to the illegal practice of selling cars without a dealer’s license, while posing as a private seller.
Why Is Curbstoning Illegal?
Licensed dealers must:
- Follow specific rules about how they advertise and sell cars
- Offer valid paperwork
- Perform specific inspections prior to selling a car
Curbstoners skip all of this, and often sell vehicles with hidden defects, salvage history, or tampered mileage that a licensed dealer would be required to disclose.
California Law
In California, Vehicle Code section 11700 et seq. requires anyone acting as a dealer to hold a valid license. Anyone selling more than 5 vehicles in a 12-month period is generally considered to be acting as a dealer. Selling without a license and posing as a private seller is illegal; violators can face fines, vehicle impoundment, and criminal penalties.
If the curbstoner also concealed damage, tampered with the odometer, or misrepresented the title, you may have additional claims. The major problem with curbstoning is that the seller disappears quickly, leaving buyers with no way to get compensation. For this reason, you should never even consider purchasing from someone that acts or sounds like a dealership but is operating out of a parking lot that does not belong to the seller.
Red Flags: How to Spot a Fake Private Seller
If you’re wondering whether you’ve been a victim of curbstoning, here are some common warning signs:
🔴 The car is parked on a street or empty lot
Not at the seller’s home. Not at a dealership.
🔴 The seller asks to meet somewhere “convenient”
Often in parking lots or gas stations.
🔴 The seller’s name isn’t on the car title
They claim it’s a family member’s or “just didn’t get around to transferring it.”
🔴 The same phone number appears on multiple listings
Search the seller’s number online—you may find other cars posted using the same contact info.
🔴 No willingness to provide ID or sign a proper bill of sale
What Happens If You Bought a Car From a Curbstoner?
You may be left with:
- A car with a salvage title you did not know about
- A vehicle that cannot pass inspection
- A lien or repossession threat from the actual owner
You need to do everything possible to find out the real idenitty of the seller and where they live because these people frequently disappear as soon as a problem arises. After securing that infomration, then consider your options for hiring an attorney or filing a small claims court case without an attorney.
Frequently Asked Questions About Curbstoning
Q: How many cars can someone sell in California before they need a dealer license?
A: Generally, more than 5 vehicles in a 12-month period requires a dealer license under Vehicle Code section 11700 et seq. Selling beyond that without a license is curbstoning.
Q: Can I sue a curbstoner if they lied about the car?
A: Potentially, though recovery can be difficult because unlicensed sellers often disappear.
Q: How do I report a curbstoner in California?
A: File a complaint with the California DMV at 1-800-777-0133 or dmv.ca.gov. DMV investigators actively target curbstoning operations and can pursue penalties against unlicensed sellers.
Q: What evidence helps a curbstoning case?
A: The original online listing (screenshot it immediately), the bill of sale, any communications with the seller, the vehicle history report, and a mechanic’s inspection documenting the vehicle’s true condition.
About the Author: Michael A. Klitzke
Michael Klitzke is the founder of Auto Law Firm, PC, handling auto fraud, lemon law, and personal injury cases throughout California’s state and federal courts. He graduated summa cum laude (2 of 201) from Thomas Jefferson School of Law, where he served as a Law Review Editor and a national mock-trial competitor, and earned his B.A. in Political Science from San Diego State University. He argued the landmark consumer case Pulliam v. HNL Automotive, Inc., 13 Cal.5th 127 (2022) before the California Supreme Court, and has been recognized by Super Lawyers (Rising Star), Best of the Bar for one of the top 100 California verdicts of 2022, and Marquis Who’s Who in North America (2025).