Tulowitzki v. Atlantic Richfield Company

396 A.2d 956, 1978 Del. LEXIS 653
CourtSupreme Court of Delaware
DecidedNovember 1, 1978
StatusPublished
Cited by47 cases

This text of 396 A.2d 956 (Tulowitzki v. Atlantic Richfield Company) is published on Counsel Stack Legal Research, covering Supreme Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tulowitzki v. Atlantic Richfield Company, 396 A.2d 956, 1978 Del. LEXIS 653 (Del. 1978).

Opinion

HERRMANN, Chief Justice:

The plaintiff, Richard C. Tulowitzki, appeals the Chancery Court’s decision that the relationship between Tulowitzki and the defendant Atlantic Richfield Company was not a “franchise” under Delaware’s Franchise Security Law, 6 Del.C. § 2551 et seq., or under the developing franchise case law; and that the vapor recovery equipment agreement that Atlantic required plaintiff to sign as part of a lease renewal was neither unconscionable nor in violation of the Delaware Retail Sales of Motor Fuel Law, 6 Del.C. Ch. 29.

I.

Tulowitzki has operated an Atlantic automobile service station in Delaware since 1968. The relationship between Tulowitzki and Atlantic has been governed by Atlantic’s lease to Tulowitzki of its service station, including land, buildings, pumps, appliances, furniture and tools. The lease authorized the use by Tulowitzki of Atlantic’s trademarks in connection with the sale of Atlantic’s products; and it provided that unless Atlantic found specific grounds for non-renewal, its policy was to renew with any lessee whose yearly sales of motor vehicle fuel exceeded 250,000 gallons. Tulow-itzki’s sales exceeded that figure.

As the July 31, 1976 expiration date on Tulowitzki’s lease approached, he was sent a new lease, the terms of which were basically the same as the previous lease. But there was a new addendum calling for rent for certain vapor recovery equipment which the Federal Environmental Protection Agency (EPA) might require at Tulowitz-ki’s station. 1 At the time, Atlantic was uncertain whether EPA would require the installation of any additional equipment, but it inserted this provision in all of its leases in order to prepare the parties for that event. The addendum required Tulow-itzki to pay Atlantic $17.54 additional rental per month for each $1,000 of Atlantic’s costs for the purchase, installation and maintenance of the vapor recovery equipment; and it provided that this cost would be computed on the basis of the average expenditures made by Atlantic throughout its system of stations rather than the actual cost of the equipment required at Tulowitz-ki’s station itself. Tulowitzki refused to sign the lease renewal because he objected to the vapor recovery addendum, whereupon he was informed by Atlantic that if he did not sign the lease by August 1,1976, the company would stop delivery of its products, refuse to honor any credit card sales made after that date, and would probably remove the ARCO identification forthwith. Atlantic rejected the suggestion that Tu-lowitzki be allowed to renew without signing the vapor recovery addendum to the lease. When Tulowitzki failed to sign by the deadline, his deliveries of Atlantic products were terminated. He thereupon obtained a temporary restraining order to maintain a supply of Atlantic petroleum products. Since Atlantic had no objection to Tulowitzki’s continuation as a lessee-dealer except for his refusal to sign the vapor recovery addendum, the preliminary injunction stage was by-passed and the par *959 ties proceeded to trial on the merits. Judgment was entered in favor of Atlantic, and the restraining order was dissolved. Tu-lowitzki appeals.

II.

The essential issue presented is whether it is unfair or unconscionable for Atlantic to require Tulowitzki to sign the vapor recovery addendum as a condition to the renewal of his service station lease. 2 Tulowitzki contends that the relationship between the parties constituted a franchise, either under the Franchise Security Law or under the developing case law [e. g. Shell Oil Co. v. Marinello, 63 N.J. 402, 307 A.2d 598 (1973)], and the relationship thus has the protection of the rule that a franchisor may not “unjustly” fail to renew a franchise. See 6 Del.C. § 2552. 3 The crux of Tulowitzki’s theory is that by insisting that he sign the vapor recovery equipment addendum as a precondition to renewal, Atlantic “constructively refused to renew” the lease without “good cause,” or acted in “bad faith,” thus “unjustly” failing to renew the lease in violation of § 2552.

The Court of Chancery held that there was no franchise under the Franchise Security Law because Tulowitzki sold products bearing the name of more than three manufacturers and therefore was not a “franchised distributor” under 6 Del.C. § 2551(l)(b). 4 The Trial Court also held the *960 Franchise Security Law inapplicable because Tulowitzki had not paid “more than $100 to enter into such contract or other arrangement.” 6 Del.C. § 2551(3). On the basis of Globe Liquor v. Four Roses Distillers Co., Del.Supr., 281 A.2d 19 (1971), the Trial Court rejected Tulowitzki’s alternative argument that a franchise existed under developing case law.

We take a different approach in reaching the same ultimate result in favor of Atlantic. Assuming, arguendo, that the relationship here involved is a franchise under the Delaware Franchise Security Law, we hold that under the totality of circumstances in this case, there was no unjust termination or failure to renew the lease without good cause, nor any act of bad faith, in violation of 6 Del.C. § 2552. Also, we find no merit in Tulowitzki’s assertion of violation of the Retail Sales of Motor Fuel Law.

III.

In order to hold Atlantic’s renewal demand “unjust”, it must be found to be unfair or unconscionable; that is to say, there must be an absence of meaningful choice and contract terms unreasonably favorable to one of the parties. Superior bargaining power alone without the element of unreasonableness does not permit a finding of unconscionability or unfairness. The traditional test is this: a contract is unconscionable if it is “such as no man in his senses and not under delusion would make on the one hand, and as no honest or fair man would accept, on the other.” Williams v. Walker-Thomas Furniture Co., 121 U.S.App.D.C. 315, 320, 350 F.2d 445, 450, 18 A.L.R.3d 1297, 1301-3 (1965). “It is generally held that the unconscionability test involves the question of whether the provision amounts to the taking of an unfair advantage by one party over the other.” J. A. Jones Construction Co. v. City of Dover, Del.Super., 372 A.2d 540, 552 (1977), appeal dismissed, Del.Supr., 377 A.2d 1 (1977).

The business-practices-of-the-community test asks whether the terms are so extreme as to appear unconscionable according to the mores and business practices of the time and place. Applying this test, it was held in Gordon v. Crown Central Petroleum Corp., N.D.Ga., 423 F.Supp.

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396 A.2d 956, 1978 Del. LEXIS 653, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tulowitzki-v-atlantic-richfield-company-del-1978.