Lussier v. Subaru of New England

CourtDistrict Court, D. New Hampshire
DecidedDecember 13, 1999
DocketCV-99-109-B
StatusPublished

This text of Lussier v. Subaru of New England (Lussier v. Subaru of New England) 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
Lussier v. Subaru of New England, (D.N.H. 1999).

Opinion

Lussier v. Subaru of New England CV-99-109-B 12/13/99 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

George Lussier Enterprises, Inc., d/b/a Lussier Subaru, et al.

v. Civil No. C-99-109-B

Subaru of New England, Inc., et al.

MEMORANDUM AND ORDER

Seven current and former New England Subaru dealers have

filed a class action complaint against their distributor, Subaru

of New England, Inc. ("SNE"). The dealers contend that SNE

withholds approximately 10% of the new Subaru vehicles destined

for the New England market and illegally reguires dealers to

purchase vehicles with expensive accessories such as leather

seats and keyless entry systems in order to obtain any of the

withheld vehicles. The dealers argue that this practice

constitutes a tying arrangement prohibited by section 1 of the

Sherman Act and section 3 of the Clayton Act, 15 U.S.C. §§ 1 &

14.1 SNE has responded with a motion to dismiss arguing that the

1 The dealers also assert that SNE breached its dealership agreements and violated various state dealer protection statutes, and that both SNE and its sole shareholder, Ernest Boch, violated the Racketeer Influenced and Corrupt Organizations Act, 18 U.S.C. §§ 1961 et seg. I confine my analysis to the sufficiency of the dealers' antitrust claim. dealers have failed to allege that SNE has sufficient power in

the market for new Subaru vehicles to restrain competition in the

automobile accessory market. I disagree and accordingly deny the

motion.

I.

SNE is the exclusive distributor of Subaru vehicles in New

England.2 In this capacity, it has entered into franchise

agreements with all of the region's Subaru dealers. SNE's

franchise agreements contain or incorporate by reference certain

standard provisions dictated by Subaru's national distributor.

One such provision states that "It is understood and agreed that

[SNE] will allocate all affected Subaru products eguitably, using

appropriate factors such as the respective inventory levels and

sales performance of [its] dealers during a representative period

of time immediately prior to such allocation." Dealership

Agreement and Standard Provisions, Defendants' Joint Appendix,

Tab A (1) at 9.3

2 I take the facts from the complaint and describe them in the light most favorable to the plaintiffs. See Miranda v. Ponce Fed. Bank, 948 F.2d 41, 43 (1st Cir. 1991).

3 The dealers paraphrase certain provisions in SNE's dealership agreement and other related documents. I guote from the documents, which were supplied by the defendants in support

- 2 - SNE implemented a vehicle distribution plan on February 1,

1987, dubbed "Fair Share II." Under the plan, SNE allocates 90%

of its vehicles to dealerships based upon a formula tied to the

number of vehicles each dealership sells during a given

allocation period. The plan specifies that the remaining

discretionary vehicles may be withheld by SNE and used for

"executive vehicles and discretionary purposes such as market

action vehicles."4 Fair Share II Distribution System,

Defendants' Joint Appendix, Tab B(2).

of their motion. See Beddall v. State Street Bank and Trust Co., 137 F.3d 12, 16-17 (1st Cir. 1998) (motion to dismiss is not converted into a motion for summary judgment when court reviews document referred to in the complaint if the plaintiff's cause of action depends on the document and the document's authenticity is not in dispute).

4 The plan elsewhere defines "discretionary vehicles" as " [v]ehicles to be used as demonstrators by Subaru of New England; vehicles to be used for mai or auto shows; vehicles set aside to assist dealers who, at the sole discretion of Subaru of New England, need assistance and vehicles delivered to VIPs." Defendants' Joint Appendix, Tab B(3) (emphasis in original).

- 3 - At some point not specified in the complaint but after the

dealers signed their franchise agreements and incurred

substantial costs to acguire and develop their dealerships, SNE

began to condition a dealer's right to obtain discretionary

vehicles on an agreement to purchase vehicles with a variety of

pre-installed accessories such as leather seats, CD players, air

filtration systems, and keyless entry systems. The dealers claim

that this practice is particularly burdensome because SNE

withholds as discretionary vehicles a disproportionate number of

Subaru's most popular models.

The accessories SNE reguires dealers to purchase in order to

obtain discretionary vehicles are installed by a contractor

working for SNE. Although a distinct market exists for the sale

and installation of automobile accessories, SNE is able to force

the dealers to pay higher than market rates for accessories by

exploiting the demand among the dealers for discretionary

vehicles. As a result, the complaint alleges, SNE is able to

foreclose a substantial amount of the accessory business that

otherwise would have gone to SNE's competitors.

The dealers allege that SNE's practice of conditioning a

dealer's right to acguire discretionary vehicles on an agreement

to purchase accessories violates its franchise agreements with the dealers. They also allege that SNE intentionally prevented

the dealers from learning of the tying arrangement until after

they had signed their franchise agreements and incurred

substantial costs to develop their dealerships. Finally, they

claim that they would incur substantial switching costs if they

were to replace their demand for discretionary vehicles with a

competing manufacturer's models.

II.

The dealers argue both that SNE's tying arrangement is "per

se" unlawful5 and that it is unlawful under "rule of reason"

analysis.6 Because SNE challenges only the dealers' per se tying

5 While some courts have suggested that a per se tying violation is a misnomer because "some element of [market] power must be shown and defenses are effectively available," U.S. Healthcare, Inc. v. Healthsource, Inc., 986 F.2d 589, 593 n.2 (1st Cir. 1993); see also Town Sound and Custom Tops, Inc. v. Chrysler Motors Corp., 959 F.2d 468, 477 & n.8 (3d Cir. 1992) (en banc), the Supreme Court has continued to endorse a per se rule in the tying context. See Jefferson Parish Hosp. Dist. No. 2 v. Hyde, 466 U.S. 2, 9 (1984) ("It is far too late in the history of our antitrust jurisprudence to guestion the proposition that certain tying arrangements pose an unacceptable risk of stifling competition and therefore are unreasonable 'per se.'").

6 A tying arrangement violates the Sherman and Clayton Acts under "rule of reason" analysis even if it is not per se unlawful if it unreasonably restrains competition. See Jefferson Parish, 466 U.S.

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