New Jersey Coalition of Automotive Retailers, Inc. v. Ford Motor Company

CourtSupreme Court of New Jersey
DecidedJuly 29, 2025
DocketA-7-24
StatusPublished

This text of New Jersey Coalition of Automotive Retailers, Inc. v. Ford Motor Company (New Jersey Coalition of Automotive Retailers, Inc. v. Ford Motor Company) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
New Jersey Coalition of Automotive Retailers, Inc. v. Ford Motor Company, (N.J. 2025).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion.

New Jersey Coalition of Automotive Retailers, Inc. v. Ford Motor Company (A-7-24) (089378)

Argued January 7, 2025 -- Decided July 29, 2025

PIERRE-LOUIS, J., writing for a unanimous Court.

In this appeal, the Court considers whether the Legislature, in defining a cause of action for violations of the Franchise Practices Act (FPA), N.J.S.A. 56:10-1 to -15, as between “[a]ny franchisee . . . against its franchisor,” id. at -10, intended that no one else -- not even a trade association of franchisees like plaintiff New Jersey Coalition of Automotive Retailers (NJCAR) -- could bring such a claim.

NJCAR “represents all of New Jersey’s franchised new car and truck retailers,” and its members include over five hundred dealerships, which is the overwhelming majority of dealerships in New Jersey. Eighteen of defendant Ford Motor Company’s Lincoln franchisees are NJCAR members, but at least one of those Lincoln dealerships was not a member during parts of this litigation. As a trade association, NJCAR represents the interests of its franchisee members but is not itself a franchisee.

NJCAR sued Ford, alleging that its Lincoln Commitment Program (LCP or the program) violates FPA provisions barring price differentials set forth in N.J.S.A. 56:10-7.4(h). The trial court found that N.J.S.A. 56:10-10 prohibits non-franchisees from bringing suit, thus denying NJCAR statutory standing in this case. NJCAR appealed, arguing that statutory standing is irrelevant because it has associational standing. The Appellate Division reversed, holding that NJCAR had associational standing. The Court granted certification. 258 N.J. 475 (2024).

HELD: Only franchisees can bring suit under the FPA. NJCAR is a trade association whose members consist of franchisee motor vehicle dealerships in New Jersey. NJCAR is not itself a motor vehicle franchisee, and it therefore lacks statutory standing to sue under the FPA.

1. Unlike the Federal Constitution, there is no express language in New Jersey’s Constitution confining judicial power to actual cases and controversies. Thus, New Jersey courts have consistently taken a more liberal approach to standing than 1 federal law. In New Jersey, nonprofit organizations have representative standing to pursue claims on behalf of their members that are of common interest and could not more appropriately be pursued by individual members. Under that logic, for example, the Education Law Center has been determined to have standing to represent public school children in Abbott districts. But there is a difference between the absence of an affirmative grant of standing and a statutory scheme so specific and focused on regulating the conduct between defined persons, entities, or groups that it unmistakably limits standing to the regulated persons, entities, or groups. Indeed, the Legislature is within its power to define -- and, thus, limit -- the class of persons entitled to bring suit under an act for injuries cognizable under that act. (pp. 10-13)

2. The FPA’s explicit purpose is “to define the relationship and responsibilities of franchisors and franchisees in connection with franchise arrangements and to protect franchisees from unreasonable termination by franchisors that may result from a disparity of bargaining power.” N.J.S.A. 56:10-2. In providing that “[a]ny franchisee may bring an action against its franchisor,” id. at -10, the FPA uses specific terms that set boundaries as to who can bring an FPA action, and against whom. The FPA defines the term “person” more broadly than “franchisor” and “franchisee.” Id. at -3, -10. The Legislature could have allowed suit by “any person,” or even “any party” or “any injured party,” but it chose not to do so. Instead, the statute’s terms are specific and provide solely that “any franchisee” can bring an FPA action against “its franchisor.” Id. at -10 (emphasis added). The use of “its” -- a possessive singular -- reinforces the purpose of the FPA as explained by the Legislature. There is no more persuasive evidence of legislative intent than the words by which the Legislature undertook to express its purpose, and the Court relies heavily on the Legislature’s narrow expressed purpose here. Applying the facts to the plain language of the statutory text, the Court holds that only franchisees can bring suit under the FPA. NJCAR is not itself a motor vehicle franchisee, and it therefore cannot bring suit under the FPA. (pp. 14-17)

3. The Court’s holding is limited solely to the FPA. The Court does not reach whether NJCAR would have associational standing to sue on behalf of its members under a different cause of action. (p. 17)

REVERSED.

CHIEF JUSTICE RABNER and JUSTICES PATTERSON, WAINER APTER, FASCIALE, NORIEGA, and HOFFMAN join in JUSTICE PIERRE-LOUIS’s opinion.

2 SUPREME COURT OF NEW JERSEY A-7 September Term 2024 089378

New Jersey Coalition of Automotive Retailers, Inc., a non-profit New Jersey Corporation,

Plaintiff-Respondent,

v.

Ford Motor Company, d/b/a Lincoln Motor Company,

Defendant-Appellant.

On certification to the Superior Court, Appellate Division.

Argued Decided January 7, 2025 July 29, 2025

Robert M. Palumbos (Duane Morris) a member of the Pennsylvania bar, admitted pro hac vice, argued the cause for appellant (Duane Morris, and Campbell Conroy & O’Neil, attorneys; Robert M. Palumbos, Andrew R. Sperl, Leah A. Mintz, William J. Conroy, and Emily J. Rogers, of counsel and on the briefs).

W. Kirby Bissell (Bass Sox Mercer) a member of the Florida bar, admitted pro hac vice, argued the cause for respondent (Genova Burns, and Bass Sox Mercer, attorneys; W. Kirby Bissell, Jennifer Borek, and Jason T. Allen (Bass Sox Mercer) of the Florida bar, admitted pro hac vice, of counsel and on the brief).

1 JUSTICE PIERRE-LOUIS delivered the opinion of the Court.

In this statutory interpretation case, we determine whether the

Legislature, in defining a cause of action for violations of the Franchise

Practices Act (FPA), N.J.S.A. 56:10-1 to -15, as between “[a]ny franchisee . . .

against its franchisor,” id. at -10, intended that no one else -- not even a trade

association of franchisees -- could bring such a claim.

The New Jersey Coalition of Automotive Retailers (NJCAR), a trade

association composed of franchisee car dealerships, brought suit for

declaratory and injunctive relief against Ford Motor Company for allegedly

violating the FPA’s prohibition on differential pricing of vehicles. Following

cross-motions for summary judgment, the trial court found that NJCAR lacked

standing because the plain text of the statute limited claims under the FPA to

those brought by a franchisee against its franchisor.

NJCAR appealed, and the Appellate Division reversed and remanded for

further proceedings. First, the Appellate Division held that NJCAR satisfied

factors for associational standing; and second, it held that New Jersey’s liberal

standing doctrine did not countenance dismissal on statutory standing grounds.

We now reverse for the reasons below. Because we find that NJCAR

lacks statutory standing under the FPA, we do not reach the question of

2 whether it would have had associational standing to sue on behalf of its

members under a different cause of action.

I.

A.

Defendant Ford Motor Company (Ford) is a Delaware corporation, with

its principal place of business in Michigan. It has a series of franchise

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New Jersey Coalition of Automotive Retailers, Inc. v. Ford Motor Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/new-jersey-coalition-of-automotive-retailers-inc-v-ford-motor-company-nj-2025.