Los Feliz Ford, Inc. v. Chrysler Group, LLC

Summarized by Martha Lowe , American Bankruptcy Institute
11 years 11 months ago

Citation:

Los Feliz Ford, Inc. dba Star Chrysler Jeep v. Chrysler Group, LLC & the U.S., No. 12-56082 (9th Cir. April 24, 2014)

Tag(s):

Ruling:

The 9th Circuit affirmed in part, reversed in part, vacated in part, and remanded following review of the district court's grant of summary judgment to Chrysler Group LLC ("Chrysler"). The 9th Circuit noted the decision was not published or appropriate for precedent except as provided by 9th Cir. R. 36-3. Providing virtually no procedural or factual context, the court ruled (a) the district court erred by granting summary judgment to Chrysler on the dealership's claim that the parties' Letter of Intent failed to satisfy the requirements of section 747(e) of the federal Consolidated Appropriations Act; (b) the district court erred by failing to analyze the dealership's Unfair Competition Law claim under California law; and (c) the district court properly granted judgment to Chrysler on the dealership's claim under the California Vehicle Code related to a "protest waiver" in the parties' Letter of Intent.

Procedural context:

The 9th Circuit reviewed the district court's grant of summary judgment. The court provided no other procedural history in the opinion. However, the court referenced an arbitrator's decision in addition to referencing the district court's grant of summary judgment. The court mentions Chrysler's bankruptcy, but makes no specific reference to the dispute being jurisdictionally based on the Chrysler bankruptcy, or any other bankruptcy.

Facts:

The 9th Circuit provided no factual background regarding the dispute. The court's discussion, however, indicated that the dispute arose out of an automobile dealership's claim against Chrysler for reinstatement as a Chrysler automobile dealership under the Consolidated Appropriations Act of 2010, a federal act. The court mentions Chrysler's bankruptcy, but makes no specific reference to the dispute arising out of, in, or being related to, the Chrysler bankruptcy, or any specific bankruptcy. The dealership appears to have challenged various operational prerequisites required by Chrysler for inclusion in its dealership network, including form sales and service agreements. The dealership and Chrysler appear to have entered into a Letter of Intent, which the dealership subsequently challenged.

Judge(s):

D.W. Nelson, Paez, and Nguyen

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