Tuesday, April 9, 2013

DeValk Lincoln Mercury, Inc. v. Ford Motor Co. case brief

DeValk Lincoln Mercury, Inc. v. Ford Motor Co. case brief summary
811 F.2d 326 (7th Cir. 1987)

CASE SYNOPSIS:
Appellants, automobile company and associated individuals, sought review of a decision by the United States District Court for the Northern District of Illinois, which granted judgment in favor of appellee automobile corporation. Appellants initiated action against appellee alleging violations of the Automobile Dealers Day in Court Act, 15 U.S.C.S. § 1221 et seq., breach of contract, breach of fiduciary duty, and fraud.

OVERVIEW:
-Appellants, automobile company and associated individuals, submitted their resignation as a car dealership to appellee automobile corporation, and the parties entered into negotiations to wind up appellant company's affairs.
-Disputes went unresolved, and appellants initiated action against appellees alleging violations of the Automobile Dealers Day in Court Act, 15 U.S.C.S. § 1221 et seq., breach of contract, breach of fiduciary duty, and fraud.
-The district court granted summary judgment in favor of appellee, and appellants sought review.

HOLDING:
The court held that, because Illinois courts had allowed parties to substitute laws of another place or country where it was not dangerous, inconvenient, immoral, nor contrary to the public policy of Illinois law, Michigan law was applicable.

ANALYSIS:
-The court held that the district court was correct in granting summary judgment as to the dispute involving the unambiguous contract.
-Because the contract was unambiguous, appellants were not permitted to offer extrinsic evidence.
-The court further held that the contract was not unconscionable because the parties had equal bargaining power.
-The court affirmed the judgment of the district court.

OUTCOME: The court affirmed a judgment of the district court granting summary judgment in favor of appellee automobile corporation in an action initiated by appellants, automobile company and associated individuals, alleging violations of the Automobile Dealers Day in Court Act, breach of contract, breach of fiduciary duty, and fraud. The court held that the district court was correct in granting summary judgment in a dispute over an unambiguous contract.

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