Bitronics Sales Co. v. Microsemiconductor Corp.

Summary

The court upheld a jury verdict awarding Bitronics Sales Company $38,000 in commissions under its sales representative agreement with Microsemiconductor Corporation. It denied post-trial motions, prejudgment interest, and relief under the Minnesota Franchise Act, concluding that the Act did not apply retroactively and that Bitronics had not paid a qualifying franchise fee. The court also declined to disturb the jury's findings regarding waiver, commissions, and the contractual termination-notice period.

Holdings

1. The $1,000 award for commissions on sales by other manufacturer representatives and the $37,000 award for commissions during the notice period were supported by the evidence and would not be disturbed.
2. Bitronics was precluded from seeking relief under Federal Rule of Civil Procedure 50(b) because it had not moved for a directed verdict during trial.
3. The jury's finding that Bitronics waived its right to commissions above five percent was supported by substantial evidence and would not be disturbed.
4. Bitronics was not entitled to prejudgment interest because its claim was unliquidated and the amount due was not readily ascertainable.
5. The Minnesota Franchise Act's good-cause termination requirements could not be applied retroactively to the parties' 1970 sales representative agreement, and the post-1975 events did not create a new agreement or material modification bringing the relationship within the Act.
6. Bitronics did not pay a direct or indirect franchise fee and therefore did not establish the statutory franchise relationship necessary for protection under the Minnesota Franchise Act.

Questions Presented

1. Whether the jury's $1,000 and $37,000 commission awards were supported by the evidence.
2. Whether the court could grant Bitronics judgment notwithstanding the verdict when Bitronics had not moved for a directed verdict during trial.
3. Whether Bitronics waived its claimed right to commissions exceeding five percent.
4. Whether Bitronics was entitled to prejudgment interest on its commission claims.
5. Whether Microsemi's termination notice was effective at the end of the contractual notice period despite its attempted earlier termination.
6. Whether the Minnesota Franchise Act and its good-cause termination requirements applied to the parties' 1970 sales representative agreement.
7. Whether Bitronics paid a direct or indirect franchise fee sufficient to satisfy the Minnesota Franchise Act.

Disposition

other