General Motors Corporation v. Mac Company

247 F. Supp. 723, 1965 U.S. Dist. LEXIS 9783, 1965 Trade Cas. (CCH) 71,620
CourtDistrict Court, D. Colorado
DecidedNovember 9, 1965
DocketCiv. A. 7989
StatusPublished
Cited by11 cases

This text of 247 F. Supp. 723 (General Motors Corporation v. Mac Company) is published on Counsel Stack Legal Research, covering District Court, D. Colorado primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
General Motors Corporation v. Mac Company, 247 F. Supp. 723, 1965 U.S. Dist. LEXIS 9783, 1965 Trade Cas. (CCH) 71,620 (D. Colo. 1965).

Opinion

WILLIAM E. DOYLE, District Judge.

This matter is before the Court on motions for summary judgment of General Motors Corporation directed to three counterclaims of the defendant.

The action was filed May 7,1963, under the 1946 Trademark Act, Title 15 U.S.C. § 1051 et seq. Relief is sought by General Motors against the alleged improper use of Chevrolet trademarks by the defendant MAC Company. A temporary injunction was entered; however, the issues raised by the complaint have not been determined and are not here considered. On June 13, 1963, defendant filed its answers and three counterclaims. The latter were based upon provisions of the 1956 Automobile Dealers Franchise Act, Title 15 U.S.C. § 1221 et seq. General Motors then answered the counterclaims and, following extensive discovery on both sides, filed the present motion for summary judgment.

Through discovery General Motors sought to expose the factual contentions of defendant MAC Company, while defendant sought evidence to support its contentions of unfair dealings by General Motors.

The first counterclaim charges that General Motors did not act in good faith in terminating a Chevrolet Dealer Franchise Agreement with the Mac Chevrolet Company of Española, New Mexico.

The second counterclaim alleges that General Motors failed to act in good faith in its refusal to renew a Chevrolet Dealer Franchise Agreement with the McMul-len Company of Alamosa, Colorado.

Counterclaim three alleges that General Motors has failed to act in good faith in the performance of its contractual duties under a Buick Dealer Franchise Agreement now in effect with the McMullen Company.

The Mac Chevrolet Company • of Es-pañola and the McMullen Company assigned their claims to the defendant here. General Motors, in response to the first counterclaim, alleges it acted in good faith in terminating the Española dealership; that it did so for cause under express provisions of the agreement. Responding to the second counterclaim, General Motors maintains it acted in good faith in refusing to renew the Ala-mosa Chevrolet dealership; that this termination resulted from a poor sales performance. Finally, in answer to the third counterclaim General Motors alleges it has acted in good faith under the Alamosa Buick dealership agreement. Other defenses are not here important.

In addition to the pleadings there are before us depositions, answers to inter *725 rogatories, admissions and affidavits. Over fourteen hundred pages of depositions, in excess of one hundred seventy exhibits, and extensive briefs have fully exposed the several controversies. Thus, there has been thorough exploration and the case would appear to be-ripe for the entry of summary judgment, absent substantial disputes with respect to material matters.

It is clear, of course, that substantial doubts are to be resolved in favor of the non-moving party and that the summary judgment remedy is to be employed with care. Zampos v. United States Smelting, Refining and Mining Co., 10 Cir., 1953, 206 F.2d 171. On the other hand, where from careful examination of all evidentiary matters presented there can be no reasonable doubt as to the existence of a genuine issue as to material facts, the device of summary judgment is an appropriate method for the disposition of a case. See Alaniz, Administrator, etc. v. United States, 10 Cir., 1958, 257 F.2d 108.

Some discussion of the pertinent provisions of the act as they affect this present litigation is in order. 1

This legislation was enacted in recognition of the disparity of economic power between automobile manufacturers and dealers and in recognition of alleged misuse by manufacturers of their power in relationship to franchised automobile dealers. A new remedy against unfair practices was provided. See Woodard v. General Motors Corp., 5 Cir., 1962, 298 F.2d 121.

The several cases decided under this act have been examined and, surprisingly, plaintiff dealers have been singularly unsuccessful. No doubt, this stems from the unusual character of this legislation — seeking as it does to regulate at least a limited phase of bargaining and contracting. There are a total of seven decisions by courts of appeal: three of these reversed district court decisions and entered judgments for defendant manufacturer; 2 two affirmed judgments entered on directed verdict for the *726 manufacturer; 3 one affirmed a judgment in favor of the manufacturer; 4 and one affirmed a summary judgment for the manufacturer. 5 From a reading of these cases it must be concluded that the act has not been interpreted in a way which substantially interferes with or modifies normal contract negotiations between the manufacturer and the dealer.

The essential requirement of the act is the exercise of “good faith.” Furthermore, the cases hold that coercion and intimidation, or threats thereof, must be proven in order to show bad faith within the prohibitions of the act. Pierce Ford Sales, Inc. v. Ford Motor Co., 2 Cir., 1961, 299 F.2d 425, 430; Globe Motors, Inc. v. Studebaker-Packard Corp., 3 Cir., 1964, 328 F.2d 645. Argument and persuasion are not ruled out and hard bargaining does not of itself subject a manufacturer to liability. Indeed, a manufacturer is not prohibited from enforcing just and reasonable contract provisions even though the same appear burdensome to dealers. It is not enough for a dealer to show inequitable results; he must also show coercive or intimidating treatment, or threats thereof.

Counsel for defendant argue that a subjective meaning should be given to the term “coercion.” The effect of this would be that any act tending to frighten or upset any given dealer must be presumed coercive. However, in our view this term implies a more objective criterion. It demands conduct on the part of the manufacturer which amounts to coercion and which results in the dealer’s acting or refraining from acting against his will. With these criteria in mind we proceed to a consideration and analysis of the facts surrounding the alleged violations.

I.

Counterclaim One deals with the cancellation of the franchise of the Mac Chevrolet Company of Española, defendant’s assignor.

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

Related

Cite This Page — Counsel Stack

Bluebook (online)
247 F. Supp. 723, 1965 U.S. Dist. LEXIS 9783, 1965 Trade Cas. (CCH) 71,620, Counsel Stack Legal Research, https://law.counselstack.com/opinion/general-motors-corporation-v-mac-company-cod-1965.