STIHL, Inc. v. New Hampshire

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In a declaratory judgment action, the State appealed a superior court order granting summary judgment in favor of plaintiff STIHL Incorporated (individually, and d/b/a Northeast STIHL). STIHL is a corporation that manufactures, distributes, and sells an array of handheld power and non-power tools such as chain saws, leaf blowers, hedge trimmers, axes, pruners, and mauls. Although many of its products have engines, none has wheels, engine and transmission, or is capable of transporting a person from one location to another. In 1981, the legislature enacted RSA chapter 357-C, the so-called “dealer bill of rights,” to regulate, among others, automotive manufacturers and dealers. the legislature increased the level of regulation it imposed. As the legislature expanded RSA chapter 357-C, it also enacted RSA chapter 347-A, a similar but less comprehensive regulatory scheme providing protections to equipment dealers. After the enactment of SB 126, STIHL sought a declaratory judgment that RSA chapter 357-C, as amended, did not apply to it. The State countered that, as a “forestry” and “yard and garden” equipment manufacturer, STIHL was subject to regulation under RSA chapter 357-C. Both parties moved for summary judgment. The trial court found that RSA chapter 347-A, before it was repealed, regulated STIHL’s agreements with its dealers because, under that statutory scheme, the legislature chose to broadly define the term “equipment.” Nevertheless, the court concluded that because STIHL produces only handheld, not ground-supported or wheeled, equipment, it falls outside of the purview of amended RSA chapter 357-C. Finding no reversible error in the superior court’s judgment, the Supreme Court affirmed. View "STIHL, Inc. v. New Hampshire" on Justia Law