Nissan North America, Inc. v. Walker-Jones Nissan, LLC

CourtCourt of Appeals of Georgia
DecidedMarch 8, 2018
DocketA17A2018
StatusPublished

This text of Nissan North America, Inc. v. Walker-Jones Nissan, LLC (Nissan North America, Inc. v. Walker-Jones Nissan, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nissan North America, Inc. v. Walker-Jones Nissan, LLC, (Ga. Ct. App. 2018).

Opinion

FIFTH DIVISION MCFADDEN, P. J., DILLARD, C. J., and BETHEL, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules

March 8, 2018

In the Court of Appeals of Georgia A17A2018. NISSAN NORTH AMERICA, INC. v. WALKER- JONES NISSAN, LLC.

PER CURIAM.

Under Georgia law, generally speaking, car dealership franchisors, such as

appellant Nissan North America, Inc., may refuse to agree to a change of ownership

or a sale of dealership assets so long as the franchisor shows that the refusal is not

arbitrary and that the proposed transferee is unfit or unqualified. Franchisors also

have a statutory “right of first refusal” (ROFR) to intervene in a proposed ownership

change or sale and thereby acquire the dealership so long as, among other things, the

original owner receives the same or better terms as the proposed transaction and the

proposed buyer is reimbursed for the expenses of having negotiated to purchase the

dealership. The question raised herein is whether these two franchisor powers operate independently. In other words, we must determine whether a franchisor exercising its

ROFR is required to show that its actions are not arbitrary and that the proposed

transferee is unfit or unqualified. For the reasons shown below, we hold that the trial

court erred by so concluding. We therefore reverse the trial court’s grant of an

interlocutory injunction and remand for further action consistent with this opinion.

With regard to the proceedings below, the record shows that on February 16,

2017, Walker-Jones Nissan, LLC filed a verified complaint against Nissan and others

and sought a temporary restraining order asking the court to block Nissan’s attempt

to exercise its ROFR in connection with a proposed sale of a Nissan dealership to

Walker-Jones. In Counts 1 and 2, Walker-Jones asserted that in attempting to exercise

its ROFR, Nissan failed to prove that its decision was not arbitrary and failed to prove

that Walker-Jones was unfit or unqualified to be a dealer based on Nissan’s prior

written standards or qualifications relating to Walker-Jones’s business experience,

moral character, and financial qualifications as required by OCGA § 10-1-653 (the

Transfer Statute). In Count 3, Walker-Jones asserted that in exercising its ROFR,

Nissan failed fully to pay Walker-Jones its reasonable expenses incurred in

connection with its negotiation and preparation to purchase the dealership as required

by the ROFR statute. See OCGA § 10-1-663.1. In Count 4, Walker-Jones asserted a

2 claim of breach of legal and private duties arising out of the Transfer Statute and the

ROFR statute. In Counts 5 and 6, it asserted claims of tortious interference. In the

remaining counts, Walker-Jones requested temporary and permanent injunctive relief,

declaratory relief, and attorney fees and costs.

Walker-Jones moved for a temporary restraining order on the ground that

Nissan was required to comply with the Transfer Statute as a part of exercising its

ROFR. The trial court granted the TRO the same day and required Walker-Jones to

provide a $10,000 bond. Three weeks later, the court held a hearing to determine

whether to extend the TRO, and on March 24, 2017, the court granted an

interlocutory injunction in favor of Walker-Jones. The court held, among other things,

(1) that Walker-Jones was likely to succeed on the merits because Nissan’s

contractual1 and statutory ROFR were subject to the Transfer Statue, (2) that Walker-

Jones would suffer irreparable injury absent injunctive relief, (3) that injunctive relief

would not disserve the public interest, and (4) that the $10,000 bond previously

1 The argument on appeal relates solely to the effect of the Transfer Statute on Nissan’s ability to exercise its ROFR. The parties do not dispute that Nissan has both a contractual and statutory ROFR. The trial court, however, did not rule whether by its terms Nissan’s contractual ROFR barred Nissan from exercising its ROFR. There is, therefore, nothing for this Court to review on that topic. See Redcedar, LLC v. CML-GA Soc. Circle, LLC, 341 Ga. App. 110, 116 (3) (798 SE2d 334) (2017); Howell v. Beauly, LLC, 337 Ga. App. 898, 901 (2) (789 SE2d 214) (2016).

3 accepted by the court was sufficient security for the interlocutory injunction. Nissan

appeals this order and contends that the trial court erred as a matter of law in making

these four rulings.

Nissan does not challenge the trial court’s findings of fact. See generally

OCGA § 9-11-52 (a) (the findings of a trial court in ruling on interlocutory

injunctions “shall not be set aside unless clearly erroneous”). The trial court’s

undisputed findings of fact show that on November 30, 2016, Walker-Jones and

certain legal entities referred to as Crosby Nissan entered into an asset purchase

agreement concerning the existing Crosby Nissan dealership located in Waycross, as

well as agreements regarding the Crosby dealership property and Crosby Nissan’s

General Motors branded dealership. In furtherance of the transaction, Crosby Nissan

and Walker-Jones provided a copy of the asset purchase agreement and the related

real estate agreement to Nissan. Nissan thereafter requested that Walker-Jones and

Crosby Nissan amend both agreements to separate the acquisition of the GM

dealership from the acquisition of Crosby Nissan, and the two parties complied.

Nissan then informed Walker-Jones that its ownership structure was unacceptable,

after which Walker-Jones made changes thereto and resubmitted to Nissan its

4 application to purchase Crosby Nissan. Nissan did not thereafter provide any further

criticism of the ownership or management structure of Walker-Jones.

Meanwhile, beginning in mid-January 2017, Nissan contacted and began

negotiating with Edgar “Woody” Folsom about a “potential business opportunity,”

and the two parties entered into a confidentiality agreement related thereto; Folsom

also provided Nissan with his personal financial statements and those of his non-

Nissan dealerships. On January 25, Folsom submitted an application to become a

Nissan dealer, and he and Nissan entered into an “Assignment and Assumption of

Right to Purchase Agreement” regarding the Crosby Nissan Dealership and related

property. Woody Folsom Nissan of Waycross, Inc. was incorporated shortly

thereafter. Therefore, as the trial court found, “while Walker-Jones Nissan was

preparing its application and submittals, Nissan was talking with Mr. Folsom

regarding his purchase of the Crosby Nissan Dealership.”

On or about January 27, 2017, Nissan notified Walker-Jones and Crosby

Nissan that it was exercising its ROFR in accordance with its Crosby Nissan

dealership agreement and Georgia law. Nissan did not provide any reason in these

letters for not agreeing to the proposed sale between Crosby Nissan and Walker-

Jones. Nor did Nissan attempt to satisfy the requirements of the Transfer Statute by

5 providing non-arbitrary reasons for its refusal to agree to the sale to Walker-Jones or

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