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West Virginia Automobile and Truck Dealers' Association v. Ford Motor Company
23-683
W. Va.
Mar 11, 2025
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Background

  • 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)
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Case Details

Case Name: West Virginia Automobile and Truck Dealers' Association v. Ford Motor Company
Court Name: West Virginia Supreme Court
Date Published: Mar 11, 2025
Docket Number: 23-683
Court Abbreviation: W. Va.