Doyle v. Phillips Petroleum Co.

527 F. Supp. 153, 1981 U.S. Dist. LEXIS 9994
CourtDistrict Court, E.D. Arkansas
DecidedOctober 30, 1981
DocketNo. B-C-75-9
StatusPublished
Cited by2 cases

This text of 527 F. Supp. 153 (Doyle v. Phillips Petroleum Co.) is published on Counsel Stack Legal Research, covering District Court, E.D. Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Doyle v. Phillips Petroleum Co., 527 F. Supp. 153, 1981 U.S. Dist. LEXIS 9994 (E.D. Ark. 1981).

Opinion

MEMORANDUM OPINION

HOWARD, District Judge.

This action involves the Emergency Petroleum Allocation Act of 1973, 15 U.S.C. § 751 et seq. (Act) and Regulations adopted pursuant to the Act.1

[155]*155The pivotal issue is whether it was a normal business practice of Phillips Petroleum Company (Phillips) to place Charles E. Doyle, doing business as Doyle Oil Company, (Doyle), on a “cash with order” for petroleum products where Doyle:

1. Had a history of being delinquent in making payments on his account.
2. In July, 1973, submitted a check drawn on an account with insufficient funds for payment of products ordered in July, 1973.
3. During the month of August, 1973, sustained a loss of operating capital when an undetermined amount of diesel fuel spilled on the ground when someone left open a valve on a six thousand gallon fuel tank.
4. During the month of August, 1973, sustained a fire loss to a television and furniture business which resulted in the closing of this business venture.
5. Was unable to obtain loans from his bank to pay for products,

when the practice of Phillips had been to ship products to Doyle on a credit arrangement which provided for payment after delivery of such products with a certain discount allowable for prompt payment as indicated hereafter.

FACTUAL BACKGROUND

In March, 1972, Doyle purchased an oil and gas distributorship from C. Ray Hanley for $35,000. Hanley received $5,000 as a down payment and agreed to receive the balance in monthly installments over a period of five years. Doyle borrowed $10,000 from the Bank of Tuckerman in order to finalize the sale and commence operations. Hanley subordinated his vendor’s lien for his unpaid balance in order to afford the Bank of Tuckerman a first mortgage for its loan to Doyle. Prior to and since the sale, the distributorship has dealt exclusively in Phillips petroleum products.

On April 15, 1972, Doyle and Phillips entered into a Jobber Sales contract for a term of two years, expiring on April 14, 1974. Under this contract, Phillips agreed to sell and Doyle to purchase light refined products — gasoline and diesel fuel-under the following payment plan:

“... One per cent (1%) discount ... [when] payment in full made within ten (10) days from the date of invoice. However, Seller may decline to make deliveries of petroleum products under this contract except for cash payable upon such delivery, whenever Seller for any reason shall have any doubt as to Buyer’s financial responsibility, and shall so advise Buyer; whereupon Buyer shall have the privilege of satisfying Seller of his or its financial responsibility, and if Seller is satisfied, deliveries may again continue hereunder upon the terms in this paragraph specified; but if Buyer fails to meet the credit requirements of Seller, Seller may terminate this contract immediately without notice; and Seller may exercise its rights under this paragraph at any time and from time to time during the continuance of this contract.”2 (Emphasis Added)

On March 21, 1974, Doyle and Phillips entered into a new Jobber Sales contract which became effective on April 15, 1974. The terms for payment specified:

Terms of payment shall be in accordance with terms established by Seller from time to time and in effect at time of delivery. Seller, however, may decline to make deliveries of said product under this contract except for cash payable upon [156]*156such delivery, whenever Seller for any reason shall have any doubt as to Buyer’s financial responsibility, and shall so advise Buyer; whereupon Buyer shall have the privilege of satisfying Seller of Buyer’s financial responsibility, and if Seller is so satisfied, deliveries may again continue hereunder upon the terms of this paragraph; but if Buyer fails to meet the credit requirements of Seller, Seller may terminate this contract immediately without notice; and Seller may exercise its rights under this paragraph at any time and from time to time during the continuance of this contract.3

Phillips designated Doyle’s credit limit at $15,000. From the very beginning, Doyle encountered credit difficulties in meeting his commitments to Phillips for products delivered. For example, between April 24, 1972, and July 30, 1973, Doyle submitted thirty-one orders for light-refined products, nine of these invoices were paid within ten days from date, while payment of twenty-two of the invoices were delinquent on the average of twenty-three days after the due dates. The delinquency period on an invoice ranged from a minimum of six days to a maximum of 140 days.

Ten orders were submitted by Doyle for tires, batteries and accessories (TBA). Four of these invoices were paid within the allotted time, but six were late ranging from a minimum of thirty-two days to a maximum of 140 days. Doyle submitted six orders for lubrication oil and greases (oil), all of which were paid late, ranging from a minimum of twenty days to a maximum of 140 days.

During the early part of 1973, Doyle was placed under “a shipment control on light-refined products” which required Doyle to make payment for an amount “equal to or in excess of his order placed to No. 1” in an effort to bring Doyle’s account into discount — 1% discount on invoices paid within ten days of the date of an invoice. Under this arrangement, Doyle’s account was within discount by May, 1973, but past due invoices began accumulating, again, almost immediately.

On August 23, 1973, a check for $1,760.13, which Doyle had transmitted to Phillips previously for payment of an invoice, was returned to Phillips because of insufficient funds. This check was not made good until approximately fourteen days after Doyle was notified of the returned check.

Also, during the month of August, 1973, Phillips received information that Doyle had sustained a loss of an undetermined quantity of diesel fuel that spilled on the ground when a valve of a six thousand gallon storage tank had been left open. Phillips further discovered that during August, 1973, Doyle sustained a fire loss to his television and furniture business and, as a consequence, this business was closed.

On October 5, 1973, Phillips, in accordance with its normal business practice, placed Doyle on a cash basis — cash submitted in advance with orders for products.

The record supports a finding that Doyle was also engaged in a trucking business. Charles Mann, Phillips district manager, testified that he visited Doyle’s premises, in connection with Phillips’ policy to assist dealers in marketing products, during the latter part of 1974, on the average of twice monthly and that he had difficulty finding Doyle at the business; that he was informed that Doyle was “off running a truck.” Doyle closed his petroleum business during the last of 1974.

Doyle contends that he did not receive notice of the credit change requiring cash with orders until January, 1974, when he attempted to order products and was advised of the change,4 and, moreover, that Phillips instituted a credit change which did [157]

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Related

Debra Chase v. Corning, Inc.
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Doyle v. Phillips Petroleum Co.
673 F.2d 1286 (Temporary Emergency Court of Appeals, 1982)

Cite This Page — Counsel Stack

Bluebook (online)
527 F. Supp. 153, 1981 U.S. Dist. LEXIS 9994, Counsel Stack Legal Research, https://law.counselstack.com/opinion/doyle-v-phillips-petroleum-co-ared-1981.