District of Columbia v. ExxonMobil Oil Corp.
172 A.3d 412
| D.C. | 2017Background
- The District of Columbia (through its Attorney General) sued ExxonMobil, two distributor entities (Anacostia and Springfield), and Capitol Petroleum Group, alleging their franchise/distribution and marketing agreements unlawfully require exclusive purchases of Exxon‑branded fuel, violating D.C. Code § 36‑303.01(a)(6) and (11) of the Retail Service Station Act (RSSA).
- The complaint alleges Exxon transferred station properties and exclusive supply rights to the Distributors, who set wholesale prices and foreclose independent dealers from sourcing cheaper Exxon‑branded fuel, harming competition, dealers, and consumers in D.C.
- Defendants moved to dismiss, arguing (1) the District lacked Article III–type standing (it failed to allege quasi‑sovereign injury under Snapp), and (2) the RSSA’s structure limited enforcement of Subchapter III to retail dealers (no express or implied AG enforcement power).
- The Superior Court granted dismissal, concluding the District failed to plead a quasi‑sovereign injury and the RSSA showed a deliberate choice not to vest Subchapter III enforcement in the Mayor/Attorney General.
- The D.C. Court of Appeals reversed: it held the Superior Court erred in requiring a quasi‑sovereign showing, concluded that a government can have standing to enforce its own laws (so long as statutory limits do not clearly preclude it), and found the RSSA does not clearly bar the independent Attorney General from suing to enforce § 36‑303.01(a)(6) and (11).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing: May the District sue in parens patriae in Superior Court to enforce RSSA provisions? | The District: sues as parens patriae to protect the public welfare and economy; alleged statutory violations constitute an injury to the District (government injured when its laws are violated). | Defendants: District lacks concrete, particularized injury; must allege quasi‑sovereign injury (Snapp) affecting a substantial segment of population. | Court: District need not plead Snapp quasi‑sovereign injury to enforce local law; alleged statutory violations suffice for injury‑in‑fact at pleading stage. Reversed dismissal on standing. |
| Nature of parens patriae: sovereign vs quasi‑sovereign requirement | District: enforcement of local statute demonstrates an interest akin to sovereign/parens patriae authority. | Defendants: Snapp requires showing quasi‑sovereign harm; District failed to do so. | Court: A state (or D.C.) may sue to enforce its laws based on sovereign interests; Snapp’s quasi‑sovereign test governs parens suits in federal courts but does not bar local enforcement suits by the State/District in its own courts. |
| Statutory authority: Does the Attorney General have power to sue to enforce Subchapter III? | District: § 1‑301.81 (2010) vests the independent Attorney General with authority and common‑law powers to ‘‘uphold the public interest’’ and control litigation; absence of express RSSA prohibition means AG is not precluded. | Defendants: RSSA’s text and structure create an enforcement scheme giving explicit roles to Mayor (Subchapters II & IV) and retail dealers (civil actions under Subchapter III); absence of express AG cause of action shows the Council did not intend public enforcement. | Court: § 1‑301.81 grants broad authority to the independent AG to pursue public‑interest litigation; RSSA does not clearly and expressly curtail that power; dismissal for lack of statutory authority was error. |
| RSSA interpretation: Did Council intend to limit enforcement of Subchapter III to private dealers? | District: legislative history and RSSA’s public‑policy statements support an enforcement role to protect consumers/competition; Council did not explicitly abrogate AG common‑law enforcement powers. | Defendants: RSSA Committee Report and provisions show Subchapter III deals with private rights; Mayor was given enforcement roles for II & IV but not III; Council’s failure to adopt bills (2011, 2014) granting AG express enforcement implies deliberate withholding. | Court: The RSSA’s text, structure, and history do not clearly preclude AG enforcement; failed legislative proposals are not persuasive evidence Congress intended to bar AG action; the AG may proceed unless statute clearly withdraws that common‑law power. |
Key Cases Cited
- Alfred L. Snapp & Son, Inc. v. Puerto Rico, 458 U.S. 592 (U.S. 1982) (articulates parens patriae/quasi‑sovereign standing principles in federal‑law suits)
- Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (U.S. 2016) (standing requires concrete and particularized injury; three‑element test reiterated)
- Vermont Agency of Natural Res. v. United States ex rel. Stevens, 529 U.S. 765 (U.S. 2000) (government has standing to vindicate injuries to its laws and proprietary interests)
- Warth v. Seldin, 422 U.S. 490 (U.S. 1975) (prudential standing limits and legislative grant of rights of action may overcome them)
- Davis v. Gulf Oil Corp., 485 A.2d 160 (D.C. 1984) (RSSA construed to permit franchisees relief under § 36‑303.01 despite lack of explicit remedy)
- In re Debs, 158 U.S. 564 (U.S. 1895) (government may seek court assistance to protect public interests; historical pedigree for sovereign enforcement)