DaimlerChrysler Vans v. Freightliner

2004 DNH 010
CourtDistrict Court, D. New Hampshire
DecidedJanuary 8, 2004
DocketCV-03-304-B
StatusPublished

This text of 2004 DNH 010 (DaimlerChrysler Vans v. Freightliner) 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
DaimlerChrysler Vans v. Freightliner, 2004 DNH 010 (D.N.H. 2004).

Opinion

DaimlerChrysler Vans v . Freightliner CV-03-304-B 01/08/04

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

DaimlerChrysler Vans LLC

v. Civil N o . 03-304-B Opinion N o . 2004 DNH 010 Freightliner of New Hampshire, Inc.

MEMORANDUM AND ORDER

DaimlerChrysler Vans (“DC Vans”) seeks a preliminary

injunction compelling Freightliner of New Hampshire, Inc.

(“Freightliner”) to arbitrate a dispute that is currently pending

before the New Hampshire Motor Vehicle Industry Board. I deny DC

Vans’ request for an injunction because federal law protects

Freightliner from having to abide by the arbitration clauses in

its dealer contracts.

I.

A. The Dealer Agreements

On October 3 1 , 2001, and November 1 4 , 2001, DC Vans entered

into agreements authorizing Freightliner to sell “Sprinter”

-1- utility vans from dealerships in Londonderry and Lebanon, New

Hampshire (the “Dealer Agreements”). The Dealer Agreements

contain clauses that obligate the parties to arbitrate “all

controversies, disputes, or claims . . . arising from or relating

to [the agreements] . . . .” (Alosa Aff. Ex. 12 Art. 18(3).)

B. The Target Agreements

The Dealer Agreements require the parties to attempt to

reach “Target Agreements” for each year that the Dealer

Agreements are in effect. One of the items that the parties must

attempt to agree on in each Target Agreement is a “Sales Volume

Objective” for the upcoming year. If the parties are unable to

agree on a Sales Volume Objective, the Dealer Agreements describe

a process by which DC Vans is authorized to establish the

objective unilaterally. Freightliner’s performances of its sales

responsibility will be evaluated in part based on its achievement

of the Sales Volume Objective. Additionally, DC Vans uses the

Sales Volume Objective in determining Freightliner’s eligibility

for certain bonuses.

DC Vans sent Freightliner proposed Target Agreements for the

Londonderry and Lebanon dealerships in March 2003.

Freightliner’s president, Joseph Alosa, signed both agreements on

-2- March 2 7 , 2003 but did not immediately return them to DC Vans.

Instead, he signed identical copies on April 7 , 2003 and sent DC

Vans the newly signed agreements. The Londonderry Target

Agreement specifies a purchase target of 60 vans and a minimum

retail sales target of 52 vans. The Derry Target Agreement

specifies a purchase target of 7 vans and a retail sales target

of 4 vans.

C. The Current Litigation

DC Vans sent Freightliner a notice on July 1 9 , 2002 stating

that: (1) it planned to introduce a new Dodge-branded Sprinter

van in 2006; (2) the new van would be sold exclusively through

Dodge dealers; and (3) until the new van was released, Sprinter

vans would be sold by both Freightliner and Dodge dealers.

On February 2 5 , 2003, Freightliner filed an administrative

protest with the New Hampshire Motor Vehicle Industry Board

challenging the changes that DC Vans proposed to make in its

Sprinter van distribution program. DC Vans responded on March

2 8 , 2003 with a demand that Freightliner submit its dispute to

arbitration. DC Vans commenced the present action after

Freightliner refused to arbitrate.

-3- II. 1

DC Vans argues that the arbitration clauses in the Dealer

Agreements require Freightliner to arbitrate the current dispute

because the dispute “aris[es] from or relat[es] to” the Dealer

Agreements. Freightliner responds by claiming that the

arbitration clauses are unenforceable under 15 U.S.C. §

1226(a)(2). Section 1226(a)(2) bars a party to a motor vehicle

1 Freightliner contends that I lack subject matter jurisdiction because state law confers exclusive jurisdiction on the Motor Vehicle Industry Board to resolve the current dispute. I disagree. The court plainly has diversity of citizenship jurisdiction to consider what essentially is a contract dispute between the parties. Because the court would have jurisdiction to address the underlying contract dispute, it has jurisdiction to consider DC Vans’ demand for arbitration. See Moses H . Cone Mem’l Hosp. v . Mercury Const. Corp., 460 U.S. 1 , 25 n.32 (1983). New Hampshire cannot adopt a law that deprives a federal court of jurisdiction to consider disputes that Congress has given it jurisdiction to address. See Begay v . Kerr-McGee Corp., 682 F.2d 1311, 1315-16 (9th Cir. 1982). Freightliner also argues that the court lacks jurisdiction based on 15 U.S.C. § 1226(a)(2). It argues that § 1226(a)(2) deprives the court of subject matter jurisdiction because it prevents the court from enforcing the arbitration clauses. Freightliner’s argument, however, concerns the merits of DC Vans’ claim rather than the court’s subject matter jurisdiction. I was initially concerned that the court may be without jurisdiction based on the Rooker-Feldman doctrine. The Supreme Court, however, has determined that the Rooker-Feldman doctrine has “no application to judicial review of executive action, including determinations made by a state administrative agency.” Verizon Md., Inc. v . Pub. Serv. Comm’n of Md., 535 U.S. 635, 644 n.3 (2002). This decision resolves my jurisdictional concern.

-4- franchise contract from enforcing an arbitration clause in the

contract unless all parties to the contract consent to

arbitration. The law applies, however, only to arbitration

agreements that are “entered into, amended, altered, modified,

renewed, or extended after November 2 , 2002.” 15 U.S.C. §

1226(b). Because the Dealer Agreements were executed prior to

November 2 , 2002, Freightliner’s argument has merit only if the

2003 Target Agreements “amended, altered or modified” the Dealer

Agreements.

DC Vans offers two arguments to support its contention that

the Target Agreements are inconsequential. First, it asserts

that the agreements merely implement the Dealer Agreements.2 I

disagree. The Target Agreements establish sales objectives for

both dealerships. These objectives were not fixed by the Dealer

2 DC Vans buttresses its argument by contending that the constitution prevents Congress from applying § 1226(a)(2) to a preexisting dealer agreement unless the “dealership agreement is modified sufficiently in substance that it can be assumed that the parties understood that one of the rights being relinquished was the right to compel arbitration of disputes.” (Pl.’s Mem. in Opp. to Mot. to Dismiss at 6.) This assertion misstates the applicable constitutional standard. A claim that a federal statute improperly alters existing contract rights is governed by the due process clause rather than the contract clause and thus is subject to a less exacting standard of review. See Pension Ben. Guar. Corp. v . R.H. Gray & Co., 467 U.S. 7 1 7 , 732-33 (1984).

-5- Agreements but instead were proposed by DC Vans and agreed to by

Freightliner. The sales objectives are significant to both

parties because they will be used to determine Freightliner’s

eligibility for bonuses.

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