Crossroads Ford Truck Sales, Inc. v. Sterling Truck Corp.
2011 IL 111611
| Ill. | 2011Background
- Crossroads Ford Truck Sales, Inc. alleged multiple violations of the Illinois Motor Vehicle Franchise Act and related contract/tort claims arising from Sterling’s decision to discontinue the Sterling line and terminate Crossroads’ franchise.
- Crossroads filed a protest with the Motor Vehicle Review Board (MVRB) alleging lack of good cause under section 4(d)(6) and sought relief including damages and injunctive relief, then dismissed protest without prejudice.
- The circuit court dismissed most counts under 2-615, ruling that some termination decisions could be considered with good cause, and allowed interlocutory appeal.
- The appellate court held the circuit court lacked subject matter jurisdiction over section 4(d)(6) damages claims and affirmed dismissal of non-4(d)(6) counts; it endorsed a two-step approach: bring 4(d)(6) claims to the MVRB first, then damages in circuit court if no good cause is found.
- This Court affirmed, holding that 4(d)(6) claims seeking damages must be brought originally in the MVRB and that the circuit court has no jurisdiction to determine good cause; if MVRB finds no good cause, damages may be pursued in circuit court under 13.
- Plaintiff’s remaining challenges to the 2-615 dismissals were deemed forfeited for not being raised in the petition for leave to appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether circuit court has jurisdiction over 4(d)(6) damages claims. | Crossroads argues it may bring 4(d)(6) damages directly in circuit court or via primary jurisdiction. | Defendants contend 4(d)(6) claims must be heard by the MVRB first, with damages later in circuit court. | No; circuit court lacks jurisdiction to determine 4(d)(6) good cause; damages may be heard only after MVRB determination. |
| Whether 4(d)(6) claims involving damages are subject to primary jurisdiction. | Plaintiff advocates a primary-jurisdiction path: circuit court original, then referral to MVRB for good cause. | Institute two-step process: first MVRB, then damages in circuit court if no good cause. | Primary jurisdiction does not apply; legislature divested circuit courts of jurisdiction for good-cause determinations under 4(d)(6). |
| Whether the proper framework is the two-step process upheld by the appellate court. | Two-step process is necessary to avoid constitutional separation-of-powers issues and ensure uniform standards. | Two-step process is the correct framework; MVRB determines good cause, damages follow in circuit court. | Correct framework is two-step: MVRB decides good cause; damages in circuit court if no good cause. |
| Effect of res judicata on subsequent damages claims after MVRB ruling. | Damages may be barred or limited by res judicata depending on forum and prior determinations. | Res judicata does not bar damages in circuit court when MVRB has determined no damages are awarded; only good-cause issues are barred. | Res judicata does not bar damages claims in circuit court when MVRB has determined good cause; only the good-cause issue is precluded. |
Key Cases Cited
- Fields Jeep-Eagle, Inc. v. Chrysler Corp., 163 Ill. 2d 462 (1994) (held circuit courts cannot determine good cause under certain franchise provisions; created MVRB)
- General Motors Corp. v. State of Illinois Motor Vehicle Review Board, 224 Ill. 2d 1 (2007) (recognizes MVRB authority and separation-of-powers considerations)
- Fields Jeep-Eagle, Inc. v. Chrysler Corp., 163 Ill. 2d 462 (1994) (development of administrative mechanism for good-cause determinations)
- NL Industries, Inc. v. Kellerman, 152 Ill. 2d 82 (1992) (discussed when a court may retain concurrent jurisdiction; need explicit divestiture)
- Skilling v. Board of Trustees, 163 Ill. 2d 286 (1994) (concurrency/ exclusivity of jurisdiction analysis; no implied divestiture)
- River Park, Inc. v. City of Highland Park, 184 Ill. 2d 290 (1998) (rule re: res judicata; final judgment on merits bar to later suits)
- In re M.W., 232 Ill. 2d 408 (2010) (assessing subject-matter jurisdiction in context of justiciable matters)
- Warren Township High School Dist. 121 v. Warren Twp. High School Fed. of Teachers, 128 Ill. 2d 155 (1989) (jurisdictional principles in educational/administrative contexts)
- Bagnola v. SmithKline Beecham Clinical Laboratories, 333 Ill. App. 3d 711 (2002) (distinguishes administrative vs. circuit court limits for certain claims)