Rhode Island Truck Center, LLC v. Daimler Trucks North America, LLC

CourtSupreme Court of Rhode Island
DecidedJuly 29, 2025
Docket2024-0047-M.P.
StatusPublished

This text of Rhode Island Truck Center, LLC v. Daimler Trucks North America, LLC (Rhode Island Truck Center, LLC v. Daimler Trucks North America, LLC) is published on Counsel Stack Legal Research, covering Supreme Court of Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rhode Island Truck Center, LLC v. Daimler Trucks North America, LLC, (R.I. 2025).

Opinion

Supreme Court

No. 2024-47-M.P. (No. 22-1913)

Rhode Island Truck Center, LLC :

v. :

Daimler Trucks North America, LLC. :

NOTICE: This opinion is subject to formal revision before publication in the Rhode Island Reporter. Readers are requested to notify the Opinion Analyst, Supreme Court of Rhode Island, 250 Benefit Street, Providence, Rhode Island 02903, at Telephone (401) 222-3258 or Email opinionanalyst@courts.ri.gov, of any typographical or other formal errors in order that corrections may be made before the opinion is published. Supreme Court

Present: Suttell, C.J., Goldberg, Robinson, Lynch Prata, and Long, JJ.

OPINION

Justice Long, for the Court. This case comes before the Court pursuant to

an order of the United States Court of Appeals for the First Circuit that certified the

following question in accordance with Article I, Rule 6(a) of the Supreme Court

Rules of Appellate Procedure:

“Can a ‘relevant market area’ in Rhode Island General Laws section 31-5.1-4.2(a) extend beyond Rhode Island’s borders?”

For the reasons set forth in this opinion, we answer the question in the affirmative—

“relevant market area” as used in G.L. 1956 § 31-5.1-4.2(a) can extend beyond

Rhode Island’s borders because the statute’s plain and unambiguous language does

not limit its extraterritorial reach.

-1- Facts and Procedural History

Because this case requires us to evaluate the text of § 31-5.1-4.2(a) and the

statutory landscape in which that section appears, we begin our discussion with an

overview of the statute. See In re Request for Advisory Opinion from House of

Representatives (Coastal Resource Management Council), 961 A.2d 930, 935 (R.I.

2008) (“Statutory construction begins with the plain text * * *.”) (quoting Raila v.

United States, 355 F.3d 118, 120 (2d Cir. 2004)); see also Bartenwerfer v. Buckley,

598 U.S. 69, 74 (2023) (“We start where we always do: with the text of the statute.”)

(brackets omitted) (quoting Van Buren v. United States, 593 U.S. 374, 381 (2021)).

The definition of “relevant market area” appears in chapter 5.1 of title 31 (the

Dealer Law), which regulates business practices among motor vehicle

manufacturers, distributors, and dealers. Chapter 5.1 of that title applies to “[a]ny

person who engages directly or indirectly in purposeful contacts within this state in

connection with the offering * * * for sale of * * * a motor vehicle within the state

* * *.” Section 31-5.1-2. The parties agree that the law applies to their businesses.

See Rhode Island Truck Center, LLC v. Daimler Trucks North America, LLC, 642

F. Supp. 3d 218, 222 (D.R.I. 2022) (RITC I).

The purpose of the Dealer Law is to prevent unfair methods of competition

and unfair or deceptive trade practices related to the sale of motor vehicles in Rhode

Island primarily by regulating the conduct of manufacturers of new motor vehicles.

-2- Sections 31-5.1-3(a), -4(b)-(d) (listing thirty-five unlawful acts in which a

manufacturer alone is barred from engaging). To that end, the law requires that a

manufacturer who seeks to establish a new motor vehicle dealership

“within * * * a relevant market area where the same line or make is then represented * * * shall in writing by certified mail first notify the [Department of Revenue] and each new motor vehicle dealer in the same line or make in the relevant market area of the intention to establish an additional dealership * * * within or into that market area.” Section 31-5.1-4.2(a).

The Dealer Law defines “relevant market area” as “the area within a radius of

twenty (20) miles around an existing dealer or the area of responsibility defined in

the franchise, whichever is greater.” Section 31-5.1-1(13). For the purposes of the

Dealer Law, the definition of “manufacturer” is any “resident or nonresident”

partnership, firm, association, corporation, or trust “who manufactures or assembles

new motor vehicles”—Daimler Trucks North America, LLC (DTNA) is a

manufacturer. Section 31-5.1-1(8). And “dealer” is defined as “every person

engaged in the business of buying, selling, or exchanging vehicles * * * and who has

an established place of business for that purpose in this state”—Rhode Island Truck

Center, LLC (RITC) is a dealer. Section 31-1-19(b). Finally, the law defines a “new

motor vehicle dealer” as “any person engaged in the business of selling, offering to

sell, soliciting, or advertising the sale of new motor vehicles and who holds * * * a

valid sales and service agreement, franchise, or contract, granted by the

-3- manufacturer * * * for the retail sale of that manufacturer’s * * * new motor

vehicles.” Section 31-5.1-1(11).

When an existing dealer receives notice under § 31-5.1-4.2(a), it has thirty

days to appeal the manufacturer’s decision to the manufacturer directly, or by filing

a protest with the Department of Revenue (the department). Section 31-5.1-4.2(a).

If an appeal is filed with the department, the department is required to notify the

manufacturer of the challenge, at which point the manufacturer “shall not establish

or relocate the proposed new motor vehicle dealership” until the department holds a

hearing, and issues a decision, on whether there is “good cause for not permitting

the new motor vehicle dealership.” Id.; see § 31-5.1-4.2(b)(1)-(12) (providing

nonexhaustive list of factors the department must evaluate to find good cause).

Here, RITC alleges that DTNA violated § 31-5.1-4.2(a) when DTNA sought

to establish a new motor vehicle dealership within RITC’s relevant market area.

DTNA had granted RITC a franchise to sell its Freightliner brand trucks in 2016. In

the fall of 2019, DTNA granted another franchise to Advantage Truck Raynham,

LLC (ATG Raynham) in Raynham, Massachusetts. Raynham, Massachusetts, is in

Bristol County, Massachusetts, which is designated in RITC’s franchise agreement

as within its “Area of Responsibility” and is therefore within RITC’s “relevant

-4- market area” under the Dealer Law.1 The instant dispute began when RITC filed a

protest challenging DTNA’s attempt to grant ATG Raynham a franchise that would

have authorized it to sell Freightliner trucks within RITC’s relevant market area.

RITC alleged that DTNA did not provide it with the statutory notice required under

§ 31-5.1-4.2(a) before attempting to grant ATG Raynham that franchise.

The “motor vehicle dealers license and hearing board” (Dealers’ Hearing

Board)—a board created under the Dealer Law to adjudicate disputes between

manufacturers and dealers—determined, however, that it lacked jurisdiction over

RITC’s protest because it could not apply the Dealer Law outside of Rhode Island

without violating the dormant Commerce Clause of the United States Constitution.

See § 31-5-2.1 (creating Dealers’ Hearing Board). RITC filed an administrative

appeal in the Superior Court which DTNA removed to the United States District

Court for the District of Rhode Island; that court likewise concluded that, under the

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