Rhоde Island Truck Center, LLC v. Daimler Trucks North America, LLC.
No. 2024-47-M.P. (No. 22-1913)
Supreme Court of Rhode Island
July 29, 2025
O P I N I O N
Justice Long, for the Court. This case comes before the Court pursuant to an order of the United States Court of Appeals for the First Circuit that certified the following question in accordance with Article I, Rule 6(a) of the Supreme Court Rules of Appellate Procedure:
“Can a ‘relevant market area’ in Rhode Island General Laws section 31-5.1-4.2(a) extend beyond Rhode Island‘s borders?”
For the reasons set forth in this opinion, we answer the question in the affirmative—“relevant market area” as used in
Because this case requires us to evaluate the text of
The definition of “relevant market area” appears in chapter 5.1 of title 31 (the Dealer Law), which regulаtes business practices among motor vehicle manufacturers, distributors, and dealers. Chapter 5.1 of that title applies to “[a]ny person who engages directly or indirectly in purposeful contacts within this state in connection with the offering * * * for sale of * * * a motor vehicle within the state * * *.”
The purpose of the Dealer Law is to prevent unfair methods of competition and unfair or deceptive trade practices related to the sale of motor vehicles in Rhode Island primarily by regulating the conduct of manufacturers of new motor vehicles.
“within * * * a relevant market area where the same line or make is then represented * * * shall in writing by certified mail first notify the [Department of Revenue] and each new motor vehicle dealer in the same line or make in the relevant market area of the intention to establish an additional dealership * * * within or into that market area.”
Section 31-5.1-4.2(a) .
The Dealer Law defines “relevant market area” as “the area within a radius of twenty (20) miles around an existing dealer or the area of responsibility defined in the franchise, whichever is greater.”
When an existing dealer receives notice under
Here, RITC alleges that DTNA violated
The “motor vehicle dealers license and hearing board” (Dealers’ Hearing Board)—a board created under the Dealer Law to adjudicate disputes between manufacturers and dealers—determined, however, that it lacked jurisdiction over RITC‘s protest because it could not apply the Dealer Law outside of Rhode Island without violating the dormant Commerce Clause of the United States Constitution. See
The First Circuit therefore certified the following question to this Court:
“Can a ‘relevant market area’ in Rhode Island General Laws section 31-5.1-4.2(a) extend beyond Rhode Island‘s borders?” RITC II, 92 F.4th at 353.
Discussion
This Court reviews certified questions de novo. Johnson v. Johnson, 264 A.3d 835, 837 (R.I. 2021). We likewise apply a de novo standard of review to questions of statutory interpretation. Id. “[S]tatutory interpretation requires this Court ‘to determine and effectuate the legislature‘s intent and to attribute to the enactment the meaning most consistent with its policies or obvious purposes.‘” Newport and New Road, LLC v. Hazard, 296 A.3d 92, 95 (R.I. 2023) (quoting Tiernan v. Magaziner, 270 A.3d 25, 30 (R.I. 2022)). “[O]ur ultimate goal is to give effect to the purpose
“It is only if the statutory language is ambiguous that we will turn to ‘our well-established maxims of statutory construction in an effort to glean the intent of the Legislature.‘” Johnson, 264 A.3d at 838 (quoting In re B.H., 194 A.3d 260, 264 (R.I. 2018)). If a statute is ambiguous—that is, “susceptible of morе than one
In our holistic reading of the Dealer Law, bearing in mind both its plain language and overriding purpose, it is our view that the law is unambiguous. As a result, we answer the certified question in the affirmative: a relevant market area can extend outside Rhode Island‘s borders under the plain meaning of the statute. A relevant market area is equal to a radius of 20 miles, or the distance provided for under the franchise agreement, whichever is greater, without regard to state borders.
In interpreting the statute, we presume that the legislature intended every word to serve some purpose and have some force and effect. Lehigh Cement Co. v. Quinn, 173 A.3d 1272, 1276 (R.I. 2017). We take judicial notice of the fact that the State of Rhode Island is only 37 miles wide. See Colonial Plumbing & Heating Supply Co. v. Contemporary Construction Co., Inc., 464 A.2d 741, 742 (R.I. 1983) (noting that a court may take judicial notice of “facts capable of accurate and ready determination by resort to sources of indisputable accuracy“). Given the state‘s size, a circle with a radius of 20 miles will always encomрass an area outside the state. In order to give the legislature‘s inclusion of the “20-mile radius” force and effect, and given the readily observable facts about the size of this state, we conclude that a “relevant market area” was intended to encompass out-of-state areas if that area is within 20 miles of an existing dealer. This reading is the only way to implement the intent of the legislature—which, presumably, was aware of the size of this state, and included the “20-mile radius” language in the definition of “relevant market area.”
Moreover, if we were to read the statute not to apply outside the state, the modifier “whichever is greater,” which appears at the end of the statutory definition of “relevant market area,” would become mere surplusage. See Rhode Island Department of Mental Health, Retardation and Hospitals v. R.B., 549 A.2d 1028,
Our holding also gives equal force to the contractual carve-out in the definition of “relevant market area.” The statute provides that a “relevant market area” is the greater of 20 miles, or the area defined in the party‘s franchise agreement. See
Our reading is further confirmed when we look to the statute as a whole. In other sections of the Dealer Law, the legislature clearly articulated when it intended for definitions and sections to apply only to in-state actors. For example, the definition of “established place of business” applies only to locations “within this state,”
Nevertheless, DTNA argues that the statute‘s silence with regard to its extraterritorial reach evinces a legislative intent that the law applies only within the state. DTNA points to the definitions of “manufacturers” and “distributors” (which
DTNA further argues that an extraterritorial application of the statute‘s plain language would lead to an absurd result because a dealer whose area of responsibility under a franchise agreement includes all of New England would be entitled to notice for the creation of a new motor vehicle dealer hundreds of miles away. This argument also fails because it would hardly be an absurd result for the terms of an agreement between two sophisticated entities to be given effect as written. See Sturbridge Home Builders, Inc. v. Downing Seaport, Inc., 890 A.2d 58, 66 n.5 (R.I. 2005) (discussing a court‘s obligation to enforce unambiguous contract terms). Indeed, were we to assume that this hypothetical were properly before us (though it is not) this Court would enforce that agreement as-written both because the рarties would be bound to the terms of their contract and because the definition of relevant market area instructs that that area is equal to the greater of 20 miles, or whatever the parties agree to in their contract. Id.;
Finally, DTNA argued, for the first time at oral argument, that the Dealer Law is ambiguous because, if this Court gave the definition of “relevant market area” an
In the end, DTNA has not presented a sound basis for this Court to rule that the statute is ambiguous, and in our review of the statutory language we see none. Therefore, our work is simple; we must give the words of the statute their “plain and ordinary meaning.” Freepoint Solar LLC, 274 A.3d at 6. In doing so, we conclude that the definition of “relevant market area” contained in
Conclusion
For the reasons stated herein, we answer the certified question in the affirmative. The papers in this case may be remanded to the United States Court of Appeals for the First Circuit for further proceedings.
Rhode Island Truck Center, LLC v. Daimler Trucks North America, LLC.
No. 2024-47-M.P. (No. 22-1913)
July 29, 2025
Associate Justice Melissa A. Long
Source of Appeal: Certified Question by the United States Court of Appeals For the First Circuit in accordance with Article I, Rule 6 of the Supreme Court Rules of Appellate Procedure. Judicial Officer from Lower Cоurt: Judges David J. Barron, Jeffrey R. Howard and Gustavo A. Gelpi of the United States Court of Appeals For the First Circuit. Attorney(s) on Appeal: For Plaintiff: Edward J. Sackman, Esq. For Defendant: Nathan D. Imfeld, Esq.