142 F.4th 67
1st Cir.2025Background
- In 2015, Tucker Cianchette attempted to purchase his father and stepmother’s interests in Casco Bay Motors, a Ford dealership in Maine, under agreements conditioned on removing Eric Cianchette’s personal guarantee with Ford’s financing arm.
- The deal fell through when Eric and Peggy Cianchette decided not to proceed, after which Tucker sued them, winning a multimillion-dollar judgment in 2016 for breach of contract and related claims; Ford employees testified in that case.
- In 2021, Eric, Peggy, Better Way Ford, and Cianchette Family, LLC sued Ford, alleging Ford had acted unlawfully during the failed negotiations and in the 2016 trial.
- Plaintiffs pursued parallel state administrative claims under Maine’s Dealers Act, which the Maine Franchise Board unanimously dismissed after a hearing.
- Plaintiffs then amended their federal complaint, alleging civil perjury, violation of the Dealers Act, breach of contract under the Sales and Service Agreement (SSA), and tortious interference; the district court dismissed all claims, leading to this appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Civil Perjury | Ford employee gave knowingly false trial testimony, affecting prior case | No plausible false testimony; or any falsity was discoverable | Not plausibly alleged; no grounds to reverse |
| Dealers Act Violation | Board’s order should not have res judicata effect given statute/evidence | Board order has preclusive effect under Maine law | Board order is preclusive; claim barred |
| Breach of Contract (SSA) | Ford breached good faith duty in not approving transaction | SSA gives Ford clear authority/discretion for approval | SSA unambiguous; implied covenant inapplicable |
| Tortious Interference with Contract | Ford’s misrepresentations led to failed deal | No plausible misrep; no justifiable reliance | No valid claim; dismissal affirmed |
Key Cases Cited
- Bean v. Cummings, 939 A.2d 676 (Me. 2008) (sets civil perjury elements under Maine law)
- Spickler v. Greenberg, 644 A.2d 469 (Me. 1994) (burden to prove witness knowingly made false statements)
- Grover v. Minette-Mills, Inc., 638 A.2d 712 (Me. 1994) (elements of tortious interference with contract)
- 20 Thames St. LLC v. Ocean State Job Lot of Maine 2017 LLC, 252 A.3d 516 (Me. 2021) (Maine's res judicata doctrine)
- Francis v. Stinson, 760 A.2d 209 (Me. 2000) (unreasonable reliance bars recovery for misrepresentation)