Dulles Mutual Benefit Ass'n v. Air Transit, Inc.

15 Va. Cir. 140
CourtLoudoun County Circuit Court
DecidedOctober 21, 1988
DocketCase No. (Law) 9956
StatusPublished

This text of 15 Va. Cir. 140 (Dulles Mutual Benefit Ass'n v. Air Transit, Inc.) is published on Counsel Stack Legal Research, covering Loudoun County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dulles Mutual Benefit Ass'n v. Air Transit, Inc., 15 Va. Cir. 140 (Va. Super. Ct. 1988).

Opinion

By JUDGE JAMES H. CHAMBLIN

This action has been brought by Dulles Mutual Benefit Association ("DMBA") and four individual plaintiffs against Air Transit, Incorporated ("Air Transit") for declaratory relief and money damages. The individual plaintiffs seek damages for an unlawful cancellation of a franchise under the Virginia Retail Franchising Act (Sections 13.1-557 et seq. of the Code of Virginia) and wrongful discharge, while DMBA seeks a declaratory judgment that certain taxicab owner/operator agreements made with Air Transit constitute franchises under the aforesaid Act. Air Transit has filed two demurrers, but only one of which has been argued and is the subject of this opinion letter.

Air Transit has filed a demurrer to DMBA’s declaratory judgment prayer alleging that DMBA has no standing to assert the cause of action and that a declaratory judgment proceeding does not lie as to the claims asserted by DMBA.

[141]*141After consideration of oral argument on October 7, 1988, and the memoranda submitted by counsel, the demurrer is sustained for the reasons hereinafter set forth.

The civil remedies provided in the Virginia Retail Franchising Act are specifically granted to a franchisee in Section 13.1-571. There is no provision granting such remedies to a group of franchisees such as the 1981 amendment to the Virginia Condominium Act, which granted unit owner associations the power to act as attorney-in-fact for the individual unit owners in asserting or defending certain actions. This amendment was passed to avoid the impact on condominium unit owner associations of the general rule as set forth in Chesapeake House v. National Bank, 231 Va. 440 (1986), that such associations do not have the standing to institute an action on behalf of its members. There are no allegations in the Motion for Judgment that the individual plaintiffs and/or the other taxicab owner/operators at Dulles Airport have designated DMBA as their attorney-in-fact to bring this suit or have otherwise legally authorized DMBA to do so.

There are no allegations in the Motion for Judgment of privity of contract between DMBA and Air -Transit or that Air Transit owed any duty to DMBA. The only contracts alleged are between the taxicab owner/operators and Air Transit. The plaintiffs challenge the agreements, but there are no allegations that DMBA is in privity of contract by assignment, third party beneficiary, or any other theory.

Even though DMBA does not have standing to bring a declaratory judgment action under Sections 8.01-184 et seq. to determine whether or not the owner-operator agreements constitute franchises under the Virginia Retail Franchising Act, I feel I must address the question of whether such issue is the appropriate subject of a declaratory judgment proceeding because the individual owner/operators may consider bringing such an action. They cannot be substituted as parties plaintiff. See Chesapeake House v. National Bank, 231 Va. 440 (1986).

I am of the opinion that seeking a judicial determination of the legal status of the owner/operators agreements is not the proper subject of a declaratory judgment proceeding. There must be an actual controversy and an actual antagonistic assertion and denial of right under Section 8.01-184. There must be specific claims based on present [142]*142facts ripe for adjudication and cannot be based on speculation of what might occur. City of Fairfax v. Shanklin, 205 Va. 227 (1964). The Court cannot be called upon to render an advisory opinion. Liberty Mutual Ins. Co. v. Bishop, 211 Va. 414 (1970); Chick v. McBain, 157 Va. 60 (1931). There are no allegations in the Motion for Judgment that all of the owner/operator agreements are exactly the same and that the circumstances surrounding the execution and performance of each are exactly the same. It would be contrary to judicial economy to require the Court to examine such factors as to each owner/operator.

For a plaintiff to recover under the civil remedies provisions of the Virginia Retail Franchising Act, he must prove that his individual case falls within the Act. It is an element of his cause of action. Each case will rise or fall on its own particular facts, and all cases may not have common facts. See Williams v. Southern Bank, 203 Va. 657 (1962). Even if this Court were to take jurisdiction and decide that, given the facts as presented in evidence, the owner/operator agreements constituted franchises, I can conceive of Air Transit in every case brought for damages asking the Court to rule it was not a franchise because the facts of the case differed from those in the declaratory judgment proceeding. Even if this Court ruled otherwise in the declaratory judgment proceeding, I can easily conceive of owner/operators bringing suit claiming that the facts in their cases were different. I feel that DMBA is asking the Court to render an advisory opinion on the franchise issue based solely on the evidence it would choose to produce at trial with potentially no res judicata or collateral estoppel effect.

I agree with the late Judge Warriner in Picture Lake Campground v. Holiday Inns, 497 F. Supp. 858 (E.D. Va. 1980), that the public policy of Virginia as expressed in the Retail Franchising Act to correct inequities in the franchising system is to be achieved primarily by the procedures of the State Corporation Commission and by criminal sanctions. Under Liberty Mutual, 211 Va. at 421, the Court must consider if some other mode of proceeding is provided. Such administrative or criminal proceedings would provide a faster resolution of the franchise issue than a declaratory judgment proceeding in this Court.

November 22, 1988

This Court can decide the franchise question in the actions asserted by the individual plaintiffs herein. Their causes of action and rights are fixed, and, thus, preferably are susceptible of resolution by traditional litigation. See American National Bank and Trust v. Kushner, 162 Va. 378 (1934). As to the other owner/operators, I feel it is speculative that their agreements will ever be cancelled by Air Transit, and, even if cancelled, under what circumstances.

Let Mr. Lawson prepare an order sustaining the demurrer to the declaratory judgment count of the Motion for Judgment as asserted by DMBA with leave to it to file an amended Motion for Judgment for a declaratory judgment on or before November 11, 1988, if it be so advised. If such an amended Motion for Judgment is so timely filed, then Air Transit will have fourteen days after filing to file its responsive pleadings thereto. If an amended Motion for Judgment is not so timely filed, then the count of the Motion for Judgment asking for a declaratory judgment will be dismissed with prejudice.

This opinion letter addresses the second demurrer filed by Air Transit, Incorporated ("Air Transit") directed toward the relief sought by the four individual plaintiffs herein. For a description of the nature of this litigation, see the first paragraph of my opinion letter dated October 21, 1988, setting forth the ruling on the demurrer to the relief requested by Dulles Mutual Benefit Association ("DMBA").

In this second demurrer, Air Transit alleges that the motion for judgment does not, for various reasons, state a claim for relief under the Virginia Retail Franchising Act (Sections 13.1-557 et seq.

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