California. See first post.
I swear that wasn't there when i posted.
So, presuming the car is 1976 or newer but more than 4 years old (if a gasoline engine) or
Older than a 1998 model or greater than 14,000 gvwr
And the seller was not a spouse, parent, grand parent, child, or grand child, or it isn't an out of state titled vehicle, yes, the seller is obligated to provide a recent smog cert (I think less than 90 days old).
If they don't you can seek a rescission. If they will not willingly comply you can sue them.
Since this is the fathers car, that is who you sue.