Andy Mohr West, Inc. v. Office of the Indiana Secretary of State
2015 Ind. App. LEXIS 578
| Ind. Ct. App. | 2015Background
- Toyota notified three Indiana Toyota dealers (Andy Mohr, Butler, Tom Wood) that it intended to relocate Ed Martin Toyota from Anderson (Madison County) to Fishers (Hamilton County, population >100,000).
- The three dealers protested and filed declaratory-judgment petitions with the Auto Dealer Services Division (the Division) under Indiana Code § 9-32-13-24(e), claiming Toyota’s proposed relocation lacked good cause.
- The Division held the applicable “relevant market area” for a dealer relocating in a county with population >100,000 is a six-mile radius (I.C. § 9-32-2-20(1)), and concluded the Dealers were outside that six-mile radius and therefore lacked standing.
- The trial court affirmed the Division’s dismissals; the Dealers appealed contesting the Division’s interpretation of “proposed [NMV] dealer” and the phrase “in a county.”
- The appellate majority reversed: it held “proposed [NMV] dealer” includes an existing dealer that is relocating into a new market, and “in a county” means relocation within the same county (so inter-county relocations fall under the ten-mile rule), and remanded for Division review on the merits.
- A dissenting judge argued the Division’s interpretation was reasonable and entitled to deference, which would leave the six-mile designation intact and affirm for lack of standing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Meaning of “proposed [NMV] dealer” in I.C. § 9-32-2-20(2)(A) | "Proposed" should include an existing dealer relocating into a market (so relocating dealers count as proposed/additional dealers). | "Proposed" means a contemplated new (not-yet-existing) dealer; relocating dealers are distinct. | Court: "proposed [NMV] dealer" includes a relocating existing dealer; Division's narrow reading is unreasonable. |
| Scope of “in a county” in I.C. § 9-32-2-20(1) | "In a county" means within the same county; an inter-county relocation is treated as entering a new market (ten-mile radius). | "In a county" covers relocations into or within a county (so an inter-county move into a >100,000 county triggers the six-mile rule). | Court: "in a county" should mean within the same county; the Division's reading (including into) produces irrational results and undermines statutory scheme. |
| Standing standard under the Dealer Services statutes | Dealers within the relevant market area (as properly defined) have standing to seek declaratory judgment and halt relocation pending Division decision. | Dealers outside the statutory relevant-market radius lack standing to file protests. | Court: Because the Division misapplied the relevant-market definitions, it erred in denying standing; remand for proceedings under correct definitions. |
| Deference to agency interpretation | Agency interpretation must be reasonable but cannot nullify statutory text; legislative purpose and harmonization control. | Agency’s interpretation is reasonable and entitled to deference even if another reasonable reading exists. | Court: Agency interpretation was unreasonable and contrary to statutory scheme; no deference owed; reversal and remand. |
Key Cases Cited
- King v. Burwell, 576 U.S. 473 (statutory interpretation requires reading the legislative plan to give effect to the statute)
- LTV Steel Co. v. Griffin, 730 N.E.2d 1251 (Ind. 2000) (agency statutory interpretations are entitled to great weight if consistent with statute)
- Pierce v. Dep’t of Corr., 885 N.E.2d 77 (Ind. Ct. App. 2008) (deference to agency where statute ambiguous; unreasonable agency interpretation receives no weight)
- Park 100 Dev. Co. v. Ind. Dep’t of State Revenue, 429 N.E.2d 220 (Ind. 1981) (statutory construction aims to effect legislative intent and harmonize provisions)
- Siwinski v. Town of Ogden Dunes, 949 N.E.2d 825 (Ind. 2011) (no part of statute should be held meaningless if it can be reconciled)
- Klotz v. Hoyt, 900 N.E.2d 1 (Ind. 2009) (related statutes should be construed in pari materia to produce harmony)
- Maschio v. Prestige Motors, 37 F.3d 908 (3d Cir. 1994) (dealer-protection statutes are remedial, addressing economic imbalances between manufacturers and local dealers)