Massachusetts State Automobile Dealers Association, Inc. v. Tesla Motors MA, Inc.

Summary

The Massachusetts Supreme Judicial Court held that the 2002 amendments to Massachusetts General Laws chapter 93B did not expand standing to allow unaffiliated motor vehicle dealers to sue manufacturers or distributors for alleged statutory violations. The court concluded that chapter 93B primarily protects dealers from unfair practices by manufacturers and distributors with which they have a franchise relationship, and that the plaintiffs’ alleged competitive injury fell outside the statute’s intended area of concern. The court affirmed dismissal of the action for lack of standing.

Holdings

1. G. L. c. 93B, § 15, does not confer standing on a motor vehicle dealer to maintain an action for violation of § 4(c)(10) against a manufacturer with which the dealer is not affiliated.
2. The plaintiffs' alleged injury from competition with an unaffiliated manufacturer was not within chapter 93B's intended area of concern.
3. The 2002 amendments broadened the protection against a manufacturer competing with its affiliated dealers by eliminating the former relevant-market-area restriction, but did not create a right for dealers to challenge competition by an unaffiliated manufacturer.

Questions Presented

1. Whether the 2002 amendments to G. L. c. 93B broadened statutory standing so that a Massachusetts motor vehicle dealer could sue an unaffiliated manufacturer or distributor for allegedly violating § 4(c)(10).
2. Whether the plaintiffs' alleged competitive injury fell within the intended area of concern of G. L. c. 93B.
3. Whether the plaintiffs had standing to pursue their statutory claims against Tesla and Tesla Motors MA.

Disposition

affirmed