STIHL, Inc. v. State
168 N.H. 332
| N.H. | 2015Background
- STIHL, Inc. manufactures handheld power and non-power tools (chain saws, blowers, trimmers, axes, pruners, mauls) that are not wheeled or ground-supported and do not transport people.
- STIHL sells primarily through about 78 authorized New Hampshire retailers and a few national account customers; it rarely sells directly to consumers.
- In 2013 the New Hampshire Legislature amended RSA chapter 357-C (the motor vehicle "dealer bill of rights") by importing the definition of "equipment" from repealed RSA chapter 347-A and providing that a "motor vehicle" "shall include equipment if sold by a motor vehicle dealer primarily engaged in the business of retail sales of equipment."
- STIHL sought a declaratory judgment that amended RSA chapter 357-C does not apply to it; the State argued STIHL’s products fall within "forestry" and "yard and garden" equipment and thus are regulated.
- The Superior Court granted summary judgment for STIHL; the State appealed. The Supreme Court reviewed statutory interpretation de novo.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether amended RSA chapter 357-C applies to STIHL’s handheld tools | STIHL: "equipment" in context of motor vehicle statute excludes handheld tools; statute’s scope and legislative history show it targets motor-vehicle-like equipment (engines, wheels, transmissions) | State: Definitions (including "forestry" and "yard and garden" equipment) unambiguously include STIHL products; applicability should depend on manufacturer–dealer relationship similar to auto dealers | Court: Ambiguous definitions; legislative history and statutory context show legislature intended a narrower scope (motor-vehicle-like equipment). RSA ch. 357-C does not apply to STIHL |
Key Cases Cited
- Favazza v. Braley, 160 A.3d 349 (N.H. 2010) (statutory interpretation principles; plain meaning and use of legislative history when ambiguous)
- State Employees Assoc. of N.H. v. N.H. Div. of Personnel, 158 A.3d 338 (N.H. 2009) (all words of a statute must be given effect; avoid superfluous language)
- State v. Breest, 167 A.3d 210 (N.H. 2014) (avoid literal interpretations that lead to absurd results)
- State v. McKeown, 159 A.3d 434 (N.H. 2009) (comment on legislative amendment authority)