Outdoor Lighting Prospectives Franchising, Inc. v. Harders

2012 NCBC 26
CourtNorth Carolina Business Court
DecidedMay 14, 2012
Docket12-CVS-4430
StatusPublished

This text of 2012 NCBC 26 (Outdoor Lighting Prospectives Franchising, Inc. v. Harders) is published on Counsel Stack Legal Research, covering North Carolina Business Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Outdoor Lighting Prospectives Franchising, Inc. v. Harders, 2012 NCBC 26 (N.C. Super. Ct. 2012).

Opinion

Outdoor Lighting Prospectives Franchising, Inc. v. Harders, 2012 NCBC 26. STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION COUNTY OF MECKLENBURG 12 CVS 4430

OUTDOOR LIGHTING ) PERSPECTIVES FRANCHISING, ) INC., ) ) Plaintiff, ) ) v. ) ORDER ON MOTION FOR ) PRELIMINARY INJUNCTION PATRICK HARDERS, OUTDOOR ) LIGHTING PERSPECTIVES OF ) NORTHERN VIRGINIA, INC. and ) ENLIGHTENED LIGHTING, LLC, ) ) Defendants. ) )

{1} THIS MATTER, designated a complex business case by Order of Chief Justice Sarah Parker dated March 28, 2012 and assigned to this court on March 30, 2012, is now before the court on Plaintiff Outdoor Lighting Perspectives Franchising, Inc.’s Motion for Preliminary Injunction (“Motion”) pursuant to Rule 65 of the North Carolina Rules of Civil Procedure (“Rule(s)”). For the reasons stated below, the Motion is GRANTED in part and DENIED in part.

Parker Poe Adams & Bernstein, LLP, by William L. Essler IV and Katie M. Iams and Gray, Plant, Mooty, Mooty & Bennett, P.A., by Michael R. Gray, pro hac vice, for Plaintiff Outdoor Lighting Perspectives Franchising, Inc.

Hagan Davis Mangum Barrett & Langley, PLLC, by Beth D. Langley and Jason B. Buckland for Defendants Patrick Harders, Outdoor Lighting Perspectives of Northern Virginia, Inc., and Enlightened Lighting, LLC.

Gale, Judge. I. SUMMARY OF HOLDING {2} Plaintiff Outdoor Lighting Perspectives Franchising, Inc. (“OLP”) seeks to enforce covenants to which it contends Defendants Patrick Harders (“Harders”) and two corporations he controls, Outdoor Lighting Perspectives of Northern Virginia, Inc. (“OLP-NV”) and Enlightened Lighting, LLC (“Enlightened”), are bound by reason of the October 23, 2006 agreement identified as Outdoor Lighting Perspectives Franchise Agreement (“Agreement”). OLP seeks a preliminary injunction pendente lite. {3} OLP began the litigation by requesting that the court enjoin Defendants from any involvement in an “outdoor lighting business.” At the hearing upon OLP’s Motion, in response to the court’s expressed concern whether the Agreement supports such a broad restriction, OLP indicated that it would be satisfied with a restriction limited to the scope of outdoor lighting business actually performed by Defendant Harders during the term of the Agreement. Defendants, on the other hand, urge that the ambiguity and breadth of the Agreement’s language precludes any injunctive relief, particularly where the Agreement seeks to reach any outdoor lighting business in its broadest context and well beyond the contours of business Harders conducted pursuant to the Agreement while it was in force. {4} While OLP champions its legal interests in protecting its franchise enterprise and invokes broad equitable principles to do so, ultimately, the court must apply the specific language OLP has chosen for that protection. And here, the court finds that the chosen language on the one hand is narrower than OLP’s invitation to restrict Defendants from a wide field of outdoor lighting, and on the other hand broader than with which the North Carolina courts have been comfortable, at least in the employment field. Admittedly, North Carolina courts are more lenient in enforcing restrictions contained in agreements attendant to the sale of a business. Here, the case involves neither employment nor the sale of a business. It arises in the context of an expired franchise agreement. A franchisor more frequently pursues post-termination enforcement in federal court because of a former franchisee’s abuse of federally protected trademark rights. In fact, OLP has recently secured injunctive relief of that nature from Judge Mullen of the United States District Court for the Western District of North Carolina. See Outdoor Lighting Perspectives Franchising, Inc. v. Home Amenities, Inc., No. 3:11-cv-0567, 2012 U.S. Dist. LEXIS 5406 (W.D.N.C. 2012). Here, however, OLP does not complain of trademark violations but of Defendants’ failure to abide by covenants restricting competition as defined under the Agreement, as well as other obligations such as the return of confidential information, including customer records. {5} Clearly, however, the primary focus of this action is to enforce the restriction on post-termination competition. The court’s analysis then must contend with the precise language of the restrictive covenant, and the defined terms embodied in the covenant. Section 14.2(b) of the Agreement contains the post- termination non-compete provision and provides: Upon termination or expiration . . . transfer, sale or assignment of this Agreement by the Franchisee, neither the Franchisee, the operating manager or the Franchisee’s owners will have any direct or indirect interest (i.e. through a relative) as a disclosed or beneficial owner, investor, partner, director, officer, employee, consultant, representative or agent, for two (2) years, in any Competitive Business within 100 miles of the Territory or any other franchisee’s Franchisor’s or Affiliates territory.

(Compl. Ex. A (“Agrmt.”) § 14.2(b).) The Agreement includes a “Definitions” section, but the term “Competitive Business” is not defined there. The term “Competitive Business” is first referenced in Section 14.2(a) of the Agreement which restricts competition by the Franchisee while the Agreement is in force. The Franchisee is prohibited by Section 14.2(a) from activity “to be used or employed in any business operating in competition with an outdoor lighting business or any business similar to the Business (“Competitive Business”) as carried on from time to time . . .” “Business” and “Outdoor Lighting Business” are defined in the Agreement’s “Definitions” section, at least when the terms are capitalized. The Agreement defines these capitalized terms to “mean[ ] the business operations conducted or to be conducted by the Franchisee consisting of outdoor lighting design and automated lighting control equipment and installation services, using the Franchisor’s System and in association therewith the Marks.” (Agrmt. at B-2−B-4.) “Franchisor’s System” or “System” means the standards, systems, concepts, identifications, methods and procedures developed or used by the Franchisor . . . for the sales and marketing of the Franchisor’s Products . . . and Services . . .” (Agrmt. at B-2−B-4.) {6} There is tension between these definitions. The scope of “Business” or “Outdoor Lighting Business” is defined in reference to the operations conducted by the individual Franchisee, which may or may not be coextensive with the Franchisor’s overall operations. The Franchisor’s overall operations, however, define the scope of the “System,” and such operations may be broader than those conducted by the individual Franchisee in its “Business.” “Competitive Business” is much more broadly stated than “Business.” “Competitive Business” extends to any business in competition with an outdoor lighting business or any business “similar to” the defined term “Business.” “Competitive Business” then is broader than the franchise “System,” “Products,” and “Services.”1 The post-termination restriction is defined in reference to “Competitive Business.” The breadth of that chosen term creates the problem Plaintiff now faces in seeking injunctive relief. Had Plaintiff limited the covenant to the defined term “Business,” it would present much less of an issue and would conform to Plaintiff’s request to limit the injunction to what Defendants did pursuant to the Agreement. But, the chosen term reaches beyond the outer limits of North Carolina court decisions upholding restrictive covenants and, as the court concludes, falls within those cases which prohibit unreasonable restrictions on competition. The court concludes the overbreadth cannot be cured by “blue penciling” as the court cannot substitute “Business” for “Competitive Business” without rewriting the Agreement.

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Bluebook (online)
2012 NCBC 26, Counsel Stack Legal Research, https://law.counselstack.com/opinion/outdoor-lighting-prospectives-franchising-inc-v-harders-ncbizct-2012.