A federal court in Ohio recently granted summary judgment to an automotive manufacturer, finding that discontinuation of a certain line of commercial vehicles did not amount to termination of a franchise under the Ohio Motor Vehicle Dealer Act (OMVDA). MD Auto Group, LLC v. Nissan North America, Inc., 2025 WL 3760779 (N.D. Ohio Dec. 30, 2025).
MD Auto Group is a Nissan Business Certified Dealer; it has a dealer agreement with Nissan and executed a Supplemental Product Addendum permitting MD Auto Group to sell Nissan’s NV commercial vehicles. MD Auto Group sued Nissan in the Northern District of Ohio alleging breach of the OMVDA, breach of contract, breach of the implied covenant of good faith and fair dealing, and breach of fiduciary duty after Nissan discontinued production of the NV van line in North America. MD Auto Group alleged that the Supplemental Product Addendum that permitted MD Auto Group to sell NV vehicles was in fact a separate franchise. MD Auto Group thus contended that Nissan breached the parties’ contract and the OMVDA when Nissan announced its discontinuation of the NV line with less than 12 months’ notice and did not compensate MD Auto Group for the discontinuation.
Nissan moved for summary judgment, arguing that MD Auto Group had one franchise under the Dealer Sales and Service Agreement. Nissan asserted that the Supplemental Product Addendum and MD Auto Group’s status as a Business Certified Dealer did not create a separate franchise for the NV line, and therefore discontinuation of the NV line did not terminate the dealer’s franchise because MD Auto Group remained an authorized Nissan dealer selling other Nissan vehicles. The district court agreed and granted summary judgment. The court found that the plain language of the OMVDA did not create a separate franchise in the NV line. Further, the court determined that the Supplemental Product Addendum was expressly incorporated into the Dealer Sales and Service Agreement and thus did not create a separate independent franchise in the NV line. Finally, the court determined that MD Auto Group’s status as a Business Certified Dealer failed to create a separate franchise in the NV line as MD Auto Group failed to show it had invested in parts and training of service employees that were rendered useless due to termination of the NV line. Ultimately, the court found that Nissan had express contractual rights permitting termination of the NV line, good faith rationale for doing so, and MD Auto Group’s franchise still existed after discontinuation of the NV line, and therefore the franchise was not terminated.