American Eagle Invests., Inc. v. Marco's Franchising, L.L.C.

2024 Ohio 3038, 250 N.E.3d 677
CourtOhio Court of Appeals
DecidedAugust 9, 2024
DocketL-23-1182
StatusPublished

This text of 2024 Ohio 3038 (American Eagle Invests., Inc. v. Marco's Franchising, L.L.C.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Eagle Invests., Inc. v. Marco's Franchising, L.L.C., 2024 Ohio 3038, 250 N.E.3d 677 (Ohio Ct. App. 2024).

Opinion

[Cite as American Eagle Invests., Inc. v. Marco’s Franchising, L.L.C., 2024-Ohio-3038.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT LUCAS COUNTY

American Eagle Investments, Inc. Court of Appeals No. L-23-1182

Appellant Trial Court No. CI0202201831

v.

Marco’s Franchising, LLC DECISION AND JUDGMENT

Appellee Decided: August 9, 2024

*****

Peter R. Silverman, Matthew T. Kemp, and Nicholas A. Huckaby, for appellant.

Anthony J. Calamunci, Amy L. Butler, and W. Barry Blum, for appellee.

***** MAYLE, J.

{¶ 1} Plaintiff-appellant, American Eagle Investments, Inc., appeals the July 12,

2023 judgment of the Lucas County Court of Common Pleas, granting summary

judgment in favor of defendant-appellee, Marco’s Franchising, LLC. For the following

reasons, we reverse the trial court judgment. I. Background {¶ 2} American Eagle Investments, Inc. is a Georgia corporation whose principal

members are George Corcoran and William Russell. Marco’s Franchising, LLC is an

Ohio limited liability company and franchisor of pizza restaurants. American Eagle and

Marco’s were parties to an Area Representative Agreement (“ARA”), pursuant to which

American Eagle served as Marco’s area representative in developing franchises within a

defined territory that included Biloxi-Gulfport, Dothan, Montgomery-Selma, Mobile-

Pensacola, and Panama City.

{¶ 3} The parties entered into the ARA in 2009 for a ten-year term with the

potential for four five-year renewal terms. The first renewal was executed in April of

2019.

A. American Eagle files suit after Marco’s issues it a notice of default.

{¶ 4} On August 27, 2020, Marco’s sent American Eagle a notice of default after

learning that Russell and Corcoran, as members of an entity called Ice ‘Em, LLC, had

entered into another Area Representative Agreement to develop franchises of Jeremiah’s

Italian Ice. Although Jeremiah’s Italian Ice is in the business of selling frozen desserts

and is not in the business of selling pizza or other products similar to Marco’s, Marco’s

maintained that American Eagle violated the following provisions of the ARA:

Section 6.2. Area Representative’s business shall be under the

active full-time management (as more fully set forth in section 6.18) of

Area Representative. If Area Representative is a corporation, partnership,

limited liability company, or limited liability partnership, such management

2. must be by one or more of Area Representative’s Principal Owners who are

designated to supervise the operation of the business contemplated under

this agreement and to have been previously approved by Franchisor or (the

“Managing Operator”). . . .

Section 6.18. Area Representative (or if Area Representative is a

corporation, partnership, limited liability company, the Managing Operator)

or one of Area Representative’s [Area Representative Operations Field

Consultants (“AR-OFCs”)] shall devote his or her full-time efforts, of not

less than 40 hours per week, to the management and attention of the Area

Representative business. . . .

Section 15.1. Area Representative covenants that during the Term

of this Agreement, except as otherwise approved in writing by Franchisor,

Area Representative (or if Area Representative is a corporation,

partnership, or limited liability company, the Managing Operator) or Area

Representative’s Manager shall devote full time, energy, and best efforts to

the management and operation of the Area Representative Business in full

compliance with the Area Representative Manual.

Section 16.1.4. Area Representative shall confine its activities to

only: (a) conducting the business licensed under this Agreement; and (b)

conducting the business licensed under a franchise agreement with

Franchisor.

3. {¶ 5} American Eagle responded to Marco’s notice of default letter and denied

that it had violated the provisions of the ARA. Having received no response from

Marco’s in response to its letter, American Eagle filed suit on September 24, 2020,

seeking declaratory judgment (Count I) and alleging violations of R.C. 1334.03(B)

(making false or misleading statement or engaging in deceptive or unconscionable act or

practice) (Count II). The next day, it moved for a temporary restraining order and

preliminary injunction, which the trial court heard on October 9, 2020, and denied in an

opinion filed October 19, 2020. Following the court’s denial of American Eagle’s

motion for preliminary injunction, Marco’s terminated the ARA.

{¶ 6} Marco’s moved for summary judgment on September 13, 2021. American

Eagle was granted an extension of time to file a response. When it sought a second

extension under Civ.R. 56(F), Marco’s opposed the motion and the court denied it,

prompting American Eagle to voluntarily dismiss the action without prejudice under

Civ.R. 41(A)(1)(a).

{¶ 7} American Eagle refiled its complaint on March 22, 2022, this time alleging

breach of contract (Count I) and declaratory judgment (Count II). The court issued a case

management order setting deadlines for discovery, mediation, expert-witness disclosure,

dispositive motions, a final settlement pretrial, and trial. Marco’s moved to transfer

pleadings, discovery, and transcripts from the first-filed case; the trial court granted its

motion.

4. B. Marco’s moves for summary judgment in the refiled action. {¶ 8} On March 16, 2023, Marco’s again moved for summary judgment. It

explained that Corcoran and Russell are the Principal Owners of the Area Representative

(“AR”), American Eagle, and they, on behalf of American Eagle, agreed to seek and

develop potential Marco’s franchisees, assist those franchisees in opening their Marco’s

stores, train them, provide ongoing support, and perform store visits to ensure that stores

were operated in accordance with Marco’s standards. In consideration for those services,

American Eagle was paid a percentage of initial franchise fees and monthly royalties

collected at the stores they developed.

{¶ 9} When American Eagle renewed its ARA with Marco’s, Corcoran and

Russell signed a general release as Principal Owners of the AR. According to Marco’s,

this general release obligated Corcoran and Russell to perform under the ARA, and

particularly under Sections 6.2, 6.18, 15.1, and 16.1.4, set forth above. Marco’s

maintained that Corcoran and Russell owed similar duties to Jeremiah’s as personal

guarantors under Ice ‘Em’s ARA with that franchising system.

{¶ 10} As it claimed in its notice of default, Marco’s insisted that as a matter of

law, the ARA with Jeremiah’s prevented American Eagle’s Managing Operators (i.e.,

Corcoran and Russell) from complying with the following provisions of the Marco’s

ARA: (1) Section 6.2, which required that the AR’s business be under the “active full-

time management” of the AR’s Managing Operator (defined as “one or more of Area

Representative’s Principal Owners who are designated to supervise the operation of the

business . . . and who have been previously approved by” Marco’s); (2) Section 6.18,

5. which required the Managing Operator or AR-OFC to devote “full-time efforts” of “not

less than 40 hours per week” to the “management and attention” of Marco’s business; (3)

Section 15.1, which required the Managing Operator or AR’s manager to “devote full-

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2024 Ohio 3038, 250 N.E.3d 677, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-eagle-invests-inc-v-marcos-franchising-llc-ohioctapp-2024.