Colonial Imports v. Volvo

CourtDistrict Court, D. New Hampshire
DecidedJanuary 9, 2001
DocketCV-98-342-B
StatusPublished

This text of Colonial Imports v. Volvo (Colonial Imports v. Volvo) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Colonial Imports v. Volvo, (D.N.H. 2001).

Opinion

Colonial Imports v. Volvo CV-98-342-B 01/09/01 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Colonial Imports Corporation d/b/a Volvo of Nashua

v. Civil No. 98-342-B Opinion NO. 01DNH008 Volvo Cars of North America, Inc.

MEMORANDUM AND ORDER

Colonial Imports Corporation, a retail automobile dealership

owned and operated by Wilfrid Piekarski, alleges that Volvo Cars

of North America, Inc., a distributor of automobiles, automobile

parts, and accessories, violated the New Hampshire Motor Vehicle

Franchise Act, N.H. Rev. Stat. Ann. § 357-C:1 et seq., by

instituting a flawed dealer incentive program and then

administering that program to the financial detriment of

Colonial. Colonial also asserts various other state law claims

for relief based on this same course of conduct. I have before

me Volvo’s motion for summary judgment, (Doc. N o . 3 9 ) . For the

reasons set forth below, I grant Volvo’s motion. I. BACKGROUND1

In 1986, Colonial entered into an agreement with Volvo to

sell and service its automobiles. The parties’ business

relationship initially appeared to be successful. Colonial was

consistently one of Volvo’s top dealers in New England in terms

of sales volume during the 1990's. This sales volume, combined

with Colonial’s high scores on customer satisfaction surveys,

enabled Colonial to receive $2,200,000 in cash incentive payments

under Volvo’s “Dealer of Excellence” program between 1992 and

1995.

A. The Partnering for Excellence Program

Volvo began to experience a downturn in its business during

the early 1990s. Competition increased during this period, sales

dropped from the record highs of the 1980's, and profits

declined. J.D. Power & Associates, a leading automobile industry

analyst, ranked Volvo in the bottom quartile of the industry for

customer satisfaction. Moreover, Volvo’s competitors began to

aggressively upgrade their facilities and dealership staff.

1 I describe the background facts in the light most favorable to Colonial, the nonmoving party. -2- In 1996, in response to this competitive environment, Volvo

encouraged its dealers to improve their facilities, hire new

employees and/or extensively retrain old employees through a

program known as “Partnering for Excellence” (“PFE”). The goal

of the PFE program was to improve Volvo’s J.D. Power customer

satisfaction ratings and, ultimately, its sales.

Volvo recognized that the improvements it wanted would place

a serious financial burden on its dealers. As an incentive to

encourage dealers to upgrade their facilities and staff, the PFE

program provided that a dealer could receive cash awards, in

addition to those available under the Dealer of Excellence

program, for every Volvo sold. In order to be eligible for PFE

awards a dealer had t o : (1) comply with certain facility and

personnel standards set by Volvo; and (2) maintain a customer

satisfaction index (“CSI”) rating of 83 in showroom satisfaction

and 70 in service satisfaction for each month during a six-month

period.2 There were two PFE periods: January 1st to June 30th

2 The CSI thresholds for the PFE program were at least as high as those for the Dealer of Excellence program. Dep. of Peter Butterfield, Ex. 1 to Aff. of W . Piekarski (hereinafter “Piekarski Aff.”), submitted with Pl.’s O b j . to Def.’s Mot. for Summ. J., (Doc. N o . 4 1 ) , at 124-25. Thus, if a dealer qualified for a PFE award, he most likely qualified for a Dealer of

-3- and July 1st to December 31st.

1. CSI Ratings

Under both the PFE program and the Dealer of Excellence

program, CSI ratings for showroom and service satisfaction were

determined by customers’ responses to surveys conducted by a

private contractor, Audits & Surveys Worldwide. Audits & Surveys

surveyed all Volvo customers who recently had purchased or leased

a new Volvo or who recently had had their Volvo serviced by a

Volvo dealer. PFE Section II §§ 3.1, 3.5, 4.1, 4.5.3 The

survey’s initial questions were “screening questions” intended to

establish that the proper person was being interviewed. PFE

Section II §§ 3.5, 4.5. Customers were then asked thirteen

showroom-related questions or fifteen service-related questions

about their experience with their Volvo dealer.4 PFE Section II

Excellence payment as well. 3 “PFE Section II” refers to “Section II - The Volvo Excellence Program Rules and Regulations” of the Partnering for Excellence documents submitted as Tab 8 in the Appendix (hereinafter “Def.’s App.”) to Volvo’s motion for summary judgment, (Doc. N o . 3 9 ) . 4 Customers also were asked a number of supplemental questions that served “as a diagnostic tool to provide a better understanding of customer expectations.” PFE Section II §§ 3.7, 4.7. Answers to these supplemental questions did not count

-4- §§ 3.6, 4.6. Customers were instructed to select from a range of

acceptable responses such as excellent, very good, good, fair, or

poor. PFE Section II §§ 3.6-.8, 4.6-.8.

A customer’s answer for each survey question was assigned a

numerical rating on a scale of zero to eight. PFE Section II §§

3.8, 4.8. For example, an answer of “excellent” rated an 8 while

an answer of “very good” rated a 4 , a “good” rated a 2 , a “fair”

rated a 1 , and a “poor” rated a 0 . Id. The numerical ratings

for the answers provided by all of the dealer’s customers were

then added together to determine its overall score. Id. Next,

the total number of answers given by all of the dealer’s

customers for each question was determined and multiplied by

eight, the highest score possible for an individual question, to

identify the dealer’s maximum achievable score for that question.

Id. For example, if fifty-four answers were received to a

particular question, fifty-four was multiplied by eight to

determine that the maximum possible score that a dealer could

receive on that question was 432. PFE Section II §3.8 (chart).

The maximum achievable scores for each question were then added

towards the dealer’s CSI rating. Id. -5- together to determine the maximum overall achievable score. PFE

Section II §3.8. Finally, the dealer’s overall score was divided

by the maximum overall achievable score to obtain its showroom or

service CSI rating. Id.

To determine the value of a dealer’s PFE award, showroom and

service CSI ratings were each converted into a dollar value

according to a sliding scale.5 PFE Section II § 5.4. The two

dollar values were then added together and multiplied by the

number of eligible cars sold.6 Id. The higher the scores, the

higher the dealer’s PFE award; a dealer could receive up to

$1,500 for each eligible new car sold. Id.

2. The PFE Program’s Impact on Dealers

Volvo’s decision to tie CSI scores directly to cash

incentives proved to be controversial, in large part because CSI

ratings were based on the results of subjective surveys. As

dealers became dependent on Dealer of Excellence and PFE

5 For example, the threshold service CSI rating of 70 has a dollar value of $100 while a perfect 100 rating has a dollar value of $750. PFE Section II § 5.4. 6 Volvo set forth a number of rules to determine whether a a car sale is eligible to be included in this multiplier. See PFE Section II §§ 5.1-.3.

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