Prakash H. Patel and Shobha P. Patel, H/w v. Sun Company, Inc. And Lancaster Associates

63 F.3d 248, 1995 U.S. App. LEXIS 23888, 1995 WL 494274
CourtCourt of Appeals for the Third Circuit
DecidedAugust 21, 1995
Docket94-2092
StatusPublished
Cited by15 cases

This text of 63 F.3d 248 (Prakash H. Patel and Shobha P. Patel, H/w v. Sun Company, Inc. And Lancaster Associates) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Prakash H. Patel and Shobha P. Patel, H/w v. Sun Company, Inc. And Lancaster Associates, 63 F.3d 248, 1995 U.S. App. LEXIS 23888, 1995 WL 494274 (3d Cir. 1995).

Opinions

OPINION OF THE COURT

ROTH, Circuit Judge:

This appeal represents the latest chapter in plaintiffs’ ongoing effort to obtain injunc-tive relief under the Petroleum Marketing Practices Act (“PMPA”), 15 U.S.C. § 2801 et seq. Specifically, plaintiffs, operators of a service station, have sought a preliminary injunction to prevent defendants from refusing to renew plaintiffs’ franchise and from evicting them from the franchise location, which plaintiffs have occupied since 1978. Plaintiffs’ initial request for injunctive relief was denied on the ground that the event required to trigger the enforcement provisions of the PMPA, termination or nonrenewal of a franchise, had not yet occurred. Now that the required nonrenewal has clearly occurred, the question presented by this appeal is whether injunctive relief is still an available remedy for these plaintiffs against these defendants..

I.

Defendant Sun Company, Inc., (“Sun”) is a refiner and marketer of motor fuels. In 1978, plaintiffs Prakash and Shobha Patel, husband and wife, entered into a lease and franchise relationship with Sun for the operation of a Sunoco service station. At the time of this original agreement, Sun owned the real estate on which the service station was located. This parcel also contained an office building with a parking lot.

In December 1987, Sun sold the entire parcel of land to defendant Lancaster Associates (“Lancaster”).1 Lancaster leased the service station back to Sun through September 30, 1994, and granted Sun the right to sublease it. Sun then offered to sublease the service station to the Patels for a period of three years. The sublease agreement specifically stated that Sun’s right to grant possession of the premises would be subject to an underlying lease which would expire on September 30, 1994. The sublease agreement also clearly stated that the underlying lease “might expire or nonrenew at the expiration of the initial term or any renewal option thereof.”

On May 17, 1988, before the sublease agreement had been signed, the Patels filed suit in the Eastern District of Pennsylvania, alleging that Sun and Lancaster had violated the PMPA. The Patels claimed that the PMPA entitled them to a right of first refusal before the franchise location could be sold and that Sun had failed to grant them this right or to offer to sell the property to them.2 Accordingly, the Patels asserted that they were entitled to injunctive relief and money damages under the PMPA. On May 20, 1988, the Patels signed the sublease with Sun.3

In October 1988, the district court denied the Patels’ motion for a preliminary injunc[250]*250tion, holding that the statutory precondition for injunctive relief, nonrenewal of the franchise, had not yet occurred. Patel v. Sun Ref. & Mktg. Co., No. 88-3958, slip op. at 1-2 (E.D.Pa. Oct. 14, 1988) (“Patel I ”). On motion for reconsideration, the court affirmed its holding but invited the Patels to recast their complaint as one for declaratory judgment. Patel v. Sun Ref. & Mktg. Co., 710 F.Supp. 1023, 1024 (E.D.Pa.1989) (“Patel II”).

Although the Patels amended their complaint, the district court again denied their request for relief under the PMPA on the ground that the triggering act required under the statute, nonrenewal of the franchise, had not yet occurred. Patel v. Sun Ref. & Mktg. Co., 1992 WL 25737, at *2 (E.D.Pa.1992) (“Patel III ”). The Patels did not appeal this order.

Meanwhile, in December 1991, the Patels and Sun executed another sublease extending the term to August 20, 1994. This new sublease, like its predecessor, explicitly stated that Sun’s right to grant possession of the premises was subject to its underlying lease with Lancaster, which would expire on September 30, 1994.

On April 28, 1994, 120 days before the expiration of the sublease, Sun notified the Patels that their franchise and sublease would not be renewed due to the expiration of Sun’s underlying lease with Lancaster. The underlying lease between Sun and Lancaster expired on September 30, 1994.

After receiving notice from Sun that their franchise would not be renewed, the Patels in July 1994 commenced the instant action in district court, again alleging that the nonre-newal of their franchise was improper under the PMPA because Sun had not offered the Patels a right of first refusal before the sale to Lancaster, nor had it offered to sell the property to the Patels. In deciding the Pa-tels’ motion for a preliminary injunction, the district court found that, because Sun’s sale of the premises to Lancaster did not constitute a termination or nonrenewal of the franchise, the Patels’ rights under the PMPA were not triggered at that time. Patel v. Sun Co., 866 F.Supp. 871, 873 (E.D.Pa.1994) (“Patel IV”). The court further held that Sun’s loss of the right to grant possession of the premises due to the expiration of its underlying lease with Lancaster was a valid reason for nonrenewal under the PMPA and that, therefore, no serious question existed regarding the merits of the Patels’ PMPA claim. Id. at 873-74. Accordingly, the Pa-tels’ motion for a preliminary injunction was denied. The Patels appealed, and we granted a stay pending appeal.

II.

The PMPA regulates the relationship between motor fuel distributors, principally oil refiners, and their franchisees, principally retail gas station operators. Prior to the passage of the PMPA, evidence suggested that “distributors had been using the threat of termination or nonrenewal to compel franchisees to comply with the distributor’s marketing policies ... [and] to gain an unfair advantage in contract disputes.” Slatky v. Amoco Oil Co., 830 F.2d 476, 478 (3d Cir.1987) (in banc) (citing S.Rep. No. 731, 95th Cong., 2d Sess. 17-19, 1978 U.S.C.C.A.N. 873, 875-77) (“Senate Report”). Accordingly, in passing the PMPA, Congress sought to “protect a franchisee’s ‘reasonable expectation’ of continuing the franchise relationship while at the same time insuring that distributors have ‘adequate flexibility ... to respond to changing market conditions and consumer preferences.’ ” Id. (quoting Senate Report at 19, 1978 U.S.C.C.A.N. at 877).

In order to effectuate these purposes, the PMPA prohibits distributors from terminating or nonrenewing franchises, unless the termination or nonrenewal is based upon one of the enumerated grounds set forth in the statute. 15 U.S.C. § 2802. Most of the enumerated exceptions involve franchisee misconduct, which is not alleged in this ease. See, e.g., § 2802(b)(2)(C) (termination based upon franchisee’s failure to pay sums due under the franchise agreement); § 2802(b)(3)(B) (nonrenewal based upon “bona fide customer complaints” about franchisee’s operations); § 2802(b)(3)(C) (nonre-newal based upon franchisee’s failure to operate property “in a clean, safe, and healthful manner”).

[251]*251In addition to the exceptions for franchisee misconduct, the PMPA also authorizes non-renewal for a limited set of business reasons, two of which are involved in the instant appeal.

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Bluebook (online)
63 F.3d 248, 1995 U.S. App. LEXIS 23888, 1995 WL 494274, Counsel Stack Legal Research, https://law.counselstack.com/opinion/prakash-h-patel-and-shobha-p-patel-hw-v-sun-company-inc-and-ca3-1995.