Darling's Auto Mall v. General Motors LLC, 135 A.3d 819

Darling’s Auto Mall, a General Motors (GM) franchisee, performed warranty repairs and sought reimbursement from GM under their Dealer Sales and Service Agreement and Maine’s Dealers Act (10 M.R.S. § 1176).
Section 1176 requires franchisors to reimburse franchisees for parts at the retail rate customarily charged; Darling’s has an established parts markup of 91.7%.
Dispute: whether “core” (exchange) charges must be reimbursed by GM at the 91.7% markup. Core charges are separately stated, refunded when defective cores are returned, and not actually borne by nonwarranty customers at Darling’s.
Darling’s won in District Court, which ordered GM to reimburse core charges at the markup; GM appealed and obtained a jury trial de novo in Superior Court.
At trial the jury found the price Darling’s paid for parts excluded the core charge; the Superior Court entered judgment for GM. Darling’s moved for judgment as a matter of law, which the court denied; Darling’s appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court erred in granting a jury trial de novo	Granting jury was improper because invoice total undisputed	Grant was proper due to genuine factual dispute about whether core was included in price	Not reviewable as interlocutory here; verdict reviewable instead
Whether as a matter of law core charges must be reimbursed at 91.7% markup under §1176	§1176 has no exception; core charges are part of "parts" and must be marked up	Statute silent on cores; factual inquiry required about how cores factor into price and industry practice	Denied — reasonable view of evidence supports jury finding that cores were excluded
Whether jury instructions should have referenced §1176 or its legislative history	Jury should be instructed on §1176 so jury can decide statutory requirement for cores	Statutory interpretation is for courts, not juries; proposed instruction was argumentative and confusing	Denied — trial court properly refused statutory instruction and gave permissible instructions
Whether denial of motion for judgment as a matter of law was erroneous	Judgment as a matter of law required because statute is plain and mandates markup	Evidence and reasonable inferences permitted a contrary factual finding; jury verdict supported	Denied — review de novo but verdict supported by evidence

State v. Diana, 89 A.3d 132 (Me. 2014) (standard for viewing facts in light most favorable to verdict)
Goodell v. Andy’s Barn, 518 A.2d 719 (Me. 1986) (analogy between jury-trial-de-novo determinations and summary judgment)
Johnson v. Jones, 515 U.S. 304 (U.S. 1995) (interlocutory appeals not appropriate from determinations that factual disputes remain)
Russell v. ExpressJet Airlines, Inc., 32 A.3d 1030 (Me. 2011) (standard of review for denial of judgment as a matter of law)
State v. Tucker, 117 A.3d 595 (Me. 2015) (review of jury instructions for prejudicial error)
State v. Hanaman, 38 A.3d 1278 (Me. 2012) (requirements for vacating judgment based on refused instruction)