FCA US, LLC v. Spitzer Autoworld Akron, LLC

The previous case involving the same parties involved automobile dealerships from Michigan, Nevada, Ohio, Florida, California, and Wisconsin, whose franchise agreements were rejected during Chrysler’s bankruptcy, but who had arbitrated successfully under the Consolidated Appropriations Act of 2010, to be reinstated as dealers. The Sixth Circuit held that certain provisions of Michigan and Nevada law were preempted by the Act, but upheld, as unchallenged on appeal, the decision that similar provisions of Ohio law were not preempted. The state laws grant existing dealerships certain rights to protest the installation of competing dealerships in the same vicinity. Spitzer, a party to the previous case, explicitly declined to argue preemption of the Ohio statute. Spitzer and others are now engaged in a protest proceeding before the Ohio Motor Vehicles Dealer Board. Chrysler sued to enjoin Spitzer from relitigating the preemption issue before the Board. The Sixth Circuit affirmed a holding that collateral estoppel precludes Spitzer from raising the preemption issue. Spitzer cannot now make the argument that it “so clearly gave up” in earlier litigation with the same parties regarding the same facts. Younger abstention is not applicable because the Ohio dealer protest proceeding is unlike any of the three types of cases to which Younger applies. View "FCA US, LLC v. Spitzer Autoworld Akron, LLC" on Justia Law