West Virginia Automobile and Truck Dealers' Association v. Ford Motor Company
23-683
W. Va.Mar 11, 2025Background
- This case involves the interpretation of West Virginia Code §§ 17A-6A-1 through -17, which governs the relationship between auto manufacturers and dealerships in West Virginia.
- Ford Motor Company offered voluntary facility upgrade programs (such as the Facility Assistance Program and Lincoln Commitment Program) to its dealers, with financial incentives for compliance.
- The dealers participating in these programs completed optional image upgrades to their dealerships to qualify for incentive payments.
- In a subsequent phase, Ford changed the standards, offering a higher incentive for further upgrades; dealers who did not comply with new standards received lower or no incentive payments.
- The issue was certified to the West Virginia Supreme Court by the federal district court to determine whether such voluntary, incentive-based upgrades count as 'required and approved' under the statutory protections for dealership image upgrades.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does participation in voluntary franchise upgrade programs count as installation of image elements 'required and approved' by the manufacturer under WV law? | Dealers argue their upgrades under Ford's voluntary programs should be statutorily protected from further required upgrades within 10 years. | Ford argues that only upgrades mandated (not optional) are 'required and approved' and protected from repeat upgrades. | Majority holds voluntary program upgrades are protected; dissent: plain language only covers required, not voluntary improvements. |
Key Cases Cited
- Bullman v. D & R Lumber Co., 195 W. Va. 129 (W. Va. 1995) (statutory construction begins with statutory language)
- State ex rel. Cohen v. Manchin, 175 W. Va. 525 (W. Va. 1984) (undefined statutory terms are given common, ordinary meanings)
- Crockett v. Andrews, 153 W. Va. 714 (W. Va. 1970) (plain meaning rule for statutory interpretation)
- Brooke B. v. Ray C., 230 W. Va. 355 (W. Va. 2013) (courts should not add to statutes what legislature omitted)
- Carper v. Kanawha Banking & Trust Co., 157 W. Va. 477 (W. Va. 1974) (normal use of the disjunctive 'or' means alternatives or options)
