Darling's Ford v. Ford Motor Co.

CourtSuperior Court of Maine
DecidedApril 9, 2002
DocketPENcv-01-14
StatusUnpublished

This text of Darling's Ford v. Ford Motor Co. (Darling's Ford v. Ford Motor Co.) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Darling's Ford v. Ford Motor Co., (Me. Super. Ct. 2002).

Opinion

STATE OF MAINE PENOBSCOT, SS.

Darling’s d/b/a Darling’s Ford, Plaintiff

Ford Motor Co., Defendant

SUPERIOR COURT CIVIL ACTION Docket No. CV- Ol- 14

“hy bE “4 ey

Ji. t

. ‘ rEoE * Pet}

GARBRECHT DONA i Lary ATAY

MAY 49 2002

Order on Cross-Motions for

Summary Judgment

FILED & ENTERED SUPERIOR COURT

APR 09 2002 PENOBSCOT COUNTY

Pending before the court are the parties’ motions for summary judgment. In

association with the motions, the parties have filed written argument and other

submissions. The court has considered these materials.

Summary judgment is proper only if the record on summary judgment shows that

there are no genuine issues of material fact and that the movant is entitled to judgment as

a matter of law. See M.R.Civ.P. 56. To survive a motion for a summary judgment, the

opposing party must produce evid

dence that, if produced at trial, would be sufficient to

resist a motion for a judgment as a matter of law; "[t]he plaintiff must establish a prima

facie case for each element of the cause of action." Rodrigue v. Rodrigue, 1997 ME 99,

{8, 694 A.2d 924, 926.

The record on summary judgment establishes that Darling’s sells and services

new and used Ford vehicles pursuant to a franchise agreement between the parties.

Under the terms of the franchise agreement, Darling’

s performs warr

anty work on Ford

vehicles and, to the extent allowed by applicable law,’ is entitled to reimbursement from

' In its response to Darling’s statement of material fact, Ford asserted that Darling’s was “entitled” to reimbursement only to the extent provided by Maine law and the terms of the parties’ franchise agreement. Ford made no record reference to any portion of the

Ford for costs associated with the labor and parts. In order to receive that reimbursement, Darling’s submits a warranty claim to the defendant. Ford reimburses Darling’s at a national rate, which is below the rate authorized under Maine law. See 10 M.R.S.A. § 1076 (providing that franchisees shall be paid for parts and labor associated with warranty work, at the retail rates customarily charged by that franchisee for non-warranty work). Darling’s then submits a second claim seeking reimbursement for the difference between the statutorily required rate and Ford’s national rate. In connection with the eight claims at issue in this case, Ford approved the claims within 30 days of their submission, and Ford then paid those claims. Subsequently, more than 30 days after Ford received the claims from Darling’s, Ford “charged back” the earlier claim approvals. These “charge backs” had the effect of reversing the decisions to approve the claims that Darling’s had submitted on the warranty work.

When Ford receives a warranty claim from a franchisee such as Darling’s, the claim is approved if it is in proper form. Following that approval, Ford reviews some of - those claims. Ford’s decision of whether to review specific claims is influenced by the nature and number of warranty claims previously submitted by that franchisee. Prior to June 2000, Darling’s warranty claim history had prompted Ford to initiate a “Warranty Counseling Process” for Darling’s. As part of this process, prior to June 2000 Ford notified Darling’s of its concerns regarding Darling’s’ warranty work practices. Additionally, Ford had conducted an “initial warranty review” and then a “warranty g Process are set out in an agreement between the parties. As part of Ford’s warranty review follow-up, in August 2000 it reviewed the claims at issue in this case, concluded that they were not proper claims and charged back the payments that it had previously authorized.

Title 10 M.R.S.A. § 1176 requires a motor vehicle franchisor, such as Ford, to either approve and pay a warranty claim submitted by franchisees or disapprove such a claim. Such action must be taken within 30 days of the date the franchisor receives such

aclaim. When a warranty claim is disapproved, the franchisor must provide written

agreement, and this part of its response is therefore insufficient. See Biette v. Scott Dugas Trucking & Excavating, Inc., 676 A.2d 490, 494 (Me. 1996). The reference to Maine law, on the other hand, is a legal matter rather than a factual one, and therefore it is a proper one. notice of the disapproval and the reasons the warranty claim was rejected. Id. Section 1176-A then provides:

A manufacturer may reasonably and periodically audit a new motor vehicle dealer to determine the validity of paid claims or any charge-backs for customer or dealer incentives. Audits of incentive payments may be only for the 18-month period immediately preceding the date notifying the dealer that an audit is to be conducted.

Here, the record on summary judgment establishes that Ford approved and paid Darling’s warranty claims in a way that was timely under section 1176. However, the parties dispute whether section 1176-A then authorizes Ford to take steps that amount to a reversal of those claim approvals through the warranty review process. The issues raised by the parties’ cross-motions turn on the construction of sections 1176 and 1176-A. The Law Court has established the following principles of statutory construction: "When construing a statute, 'we look to the plain meaning of the language to give effect to the legislative intent.'... Additionally, we consider the statutory scheme as a whole in order to reach a harmonious result. . . .Lastly, '[w]e avoid statutory constructions that create absurd, illogical, or inconsistent results.’ Fairchild Semiconductor Corp v. State Tax Assessor, 1999 ME 170, | 7, 740 A.2d 584, 587 (internal citations omitted).

Here, in section 1176, the Legislature imposed obligations on a motor vehicle franchisor arising from warranty work performed by franchisees on vehicles manufactured by that franchisor. Those obligations encompass the amount of reimbursement due to the franchisee (namely, the retail rate for both parts and labor charged by that franchisor for non-warranty work) and the time within which the franchisor must take action on the warranty claim (namely, 30 days to pay or disapprove the claim). The next statutory provision, section 1176-A, authorizes the franchisor to “reasonably and periodically audit a new motor vehicle dealer to determine the validity of paid claims... .” The Legislature chose not to define the term “paid claims.” However, the plain meaning of that phrase would include a paid warranty claim within its scope. Further, its very juxtaposition to the statute controlling the payment of warranty claims indicates that one type of a “paid claim” under section 1176-A is a warranty claim that is

paid pursuant to section 1176 itself. Darling’s argues that this construction would defeat the apparent purpose of section 1176, which is to require the prompt settlement of warranty claims submitted by franchisees. First, this argument is weakened by the plain language of section 1176-A, which expressly permits a franchisor to conduct an audit of “paid claims.” Here, Ford paid the warranty claims submitted by Darling’s. The terms of section 1176-A then contemplate the very action taken here by Ford, namely, an audit of those claims that were paid previously. Further, the putative objective of section 1176 is not fundamentally undermined by a provision that permits a franchisor to review and examine paid claims, so long as those audits are conducted “reasonably and periodically.”

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Acadia Motors, Inc. v. Ford Motor Co.
44 F.3d 1050 (First Circuit, 1995)
Darling's v. Ford Motor Co.
2003 ME 21 (Supreme Judicial Court of Maine, 2003)
Ingraham v. University of Maine at Orono
441 A.2d 691 (Supreme Judicial Court of Maine, 1982)
Heber v. Lucerne-In-Maine Village Corp.
2000 ME 137 (Supreme Judicial Court of Maine, 2000)
Saga Communications of New England, Inc. v. Voornas
2000 ME 156 (Supreme Judicial Court of Maine, 2000)
McAfee v. Cole
637 A.2d 463 (Supreme Judicial Court of Maine, 1994)
North East Insurance v. Soucy
1997 ME 106 (Supreme Judicial Court of Maine, 1997)
Biette v. Scott Dugas Trucking & Excavating, Inc.
676 A.2d 490 (Supreme Judicial Court of Maine, 1996)
Hall v. Board of Environmental Protection
498 A.2d 260 (Supreme Judicial Court of Maine, 1985)
Rodrigue v. Rodrigue
1997 ME 99 (Supreme Judicial Court of Maine, 1997)
In Re Kaleb D.
2001 ME 55 (Supreme Judicial Court of Maine, 2001)
Fairchild Semiconductor Corp. v. State Tax Assessor
1999 ME 170 (Supreme Judicial Court of Maine, 1999)
Ashe v. Enterprise Rent-A-Car
2003 ME 147 (Supreme Judicial Court of Maine, 2003)
Rosen v. Harris
427 A.2d 953 (Supreme Judicial Court of Maine, 1981)

Cite This Page — Counsel Stack

Bluebook (online)
Darling's Ford v. Ford Motor Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/darlings-ford-v-ford-motor-co-mesuperct-2002.