BILL ANALYSIS                                                                                                                                                                                                    �



                                                                            



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                                    THIRD READING


          Bill No:  SB 610
          Author:   Jackson (D)
          Amended:  4/8/13
          Vote:     21

           
           SENATE JUDICIARY COMMITTEE  :  5-2, 4/16/13
          AYES:  Evans, Corbett, Jackson, Leno, Monning
          NOES:  Walters, Anderson


           SUBJECT  :    Franchises

           SOURCE  :     American Association of Franchisees and Dealers


           DIGEST  :    This bill requires the franchisors, subfranchisors,  
          and franchisees to deal with each other in good faith, as  
          defined in the performance and enforcement of a franchise  
          agreement, and prohibits a franchisor or subfranchisor from  
          restricting the right of a franchisee to join or participate in  
          an association of franchisees to the extent the restriction is  
          prohibited by existing law.

           ANALYSIS  :    

          Existing law:

          1. The California Franchise Relations Act (CFRA), generally  
             regulates the termination, nonrenewal, and certain transfers  
             of franchises with the intent to protect franchise investors.  
              

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          2. The CFRA, generally defines a franchise to mean a contract or  
             agreement, either express or implied, whether oral or  
             written, between two or more persons by which: 


             A franchisee is granted the right to engage in the business  
             of offering, selling or distributing goods or services under  
             a marketing plan or system prescribed in substantial part by  
             a franchisor; 


             The operation of the franchisee's business pursuant to that  
             plan or system is substantially associated with the  
             franchisor's trademark, service mark, trade name, logotype,  
             advertising, or other commercial symbol designating the  
             franchisor or its affiliate; and,

             The franchisee is required to pay, directly or indirectly, a  
             franchise fee.  

          3. The CFRA, prohibits franchisors, unless otherwise provided  
             under the CFRA, from terminating a franchise prior to the  
             expiration of its term, except for good cause.  Existing law  
             provides that "good cause" shall include, but is not limited  
             to, the failure of the franchisee to comply with any lawful  
             requirement of the franchise agreement after being given  
             notice thereof and a reasonable opportunity to cure the  
             failure. 

          4. The CFRA, specifies various grounds under which immediate  
             notice of termination without an opportunity to cure shall be  
             deemed reasonable. Among other things, this includes where  
             the franchisee makes any material misrepresentations relating  
             to the acquisition of the franchise business or the  
             franchisee engages in conduct which reflects materially and  
             unfavorably upon the operation and reputation of the  
             franchise business or system. 

          5. The CFRA, provides that in the event a franchisor terminates  
             or fails to renew a franchise other than in accordance with  
             the CFRA, the franchisor must offer to repurchase the  
             franchisee's resalable current inventory, as specified. 


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          6. The California Franchise Investment Law (CFIL), provides, in  
             relevant part, that it shall be a violation of the CFIL for  
             any franchisor, directly or indirectly, through any officer,  
             agent or employee, to restrict or inhibit the right of  
             franchisees to join a trade association or to prohibit the  
             right of free association among franchisees for any lawful  
             purposes. 

          7. The CFIL, permits any person who violates the above to be  
             sued in the superior court in the county in which the  
             defendant resides or where a franchise affected by the  
             violation does business, for temporary and permanent  
             injunctive relief and for damages, if any, and the costs of  
             suit, including reasonable attorney's fees.  A plaintiff  
             shall not be required to allege or prove that actual damages  
             have been suffered in order to obtain injunctive relief.

          8. The CFIL, prohibits an action from being maintained to  
             enforce any liability under Section 31220 unless it is  
             brought within two years after the violation upon which it is  
             based or within one year after the discovery by the plaintiff  
             of the facts constituting such violation, whichever occurs  
             first. 

          9. The CFIL, provides that any person who offers or sells a  
             franchise in violation of specified sections of the CFIL or  
             in violation of any provision that provides an exemption from  
             the requirements of the CFIL, as specified, shall be liable  
             to the franchisee or subfranchisor, who may sue for damages  
             caused thereby, and if the violation is willful, the  
             franchisee may also sue for rescission, unless, in specified  
             cases (provisions relating to the willful making of an untrue  
             statement of material fact or omission of a material fact),  
             the defendant proves that the plaintiff knew the facts  
             concerning the untruth or omission, or that the defendant  
             exercised reasonable care and did not know, or, if he/she had  
             exercised reasonable care, would not have known, of the  
             untruth or omission.

          This bill:

          1. Requires that franchisors, subfranchisors, and franchisees  
             deal with each other in good faith in the performance and  
             enforcement of the franchise agreement.

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          2. Prohibits a franchisor or subfranchisor from restricting the  
             right of a franchisee to join or participate in an  
             association of franchisees to the extent the restriction is  
             prohibited by the CFIL.

          3. Defines good faith to mean honesty in fact and the observance  
             of reasonable commercial standards of fair dealing in the  
             trade. 

          4. Permits a franchisee to bring suit for damages, or for  
             rescission or other relief as the court may deem appropriate,  
             if a franchisor or subfranchisor offers to sell, sells, fails  
             to renew or transfer, or terminates a franchise in violation  
             of the above requirements, and further allows the court to  
             increase the award of damages to an amount not to exceed  
             three times the actual damages sustained and to award  
             reasonable costs and attorney's fees to a prevailing  
             plaintiff.

          5. Provides that a franchisor or subfranchisor who becomes  
             liable to make payments, may recover contributions from any  
             person who, if sued separately, would have been liable to  
             make the same payments.

           Background
           
          The CFIL was enacted in 1970 to regulate franchise investment  
          opportunities in order to protect California investors from  
          flimsy or fraudulent franchise investments.  The CFIL generally  
          requires franchisors to provide prospective franchisees with the  
          information necessary to make an intelligent decision regarding  
          franchise offers, and prohibits the sale of franchises where  
          they would lead to fraud or likelihood that a franchisor's  
          promises would not be fulfilled.   

          Subsequently, the CFRA was enacted to govern the ongoing  
          relationships between franchisors and franchisees in an effort  
          to prevent unfair practices in the termination, renewal or  
          transfer of a franchise, where either the franchise is domiciled  
          in California or the franchise business is or has been operated  
          in California.  For example, the CFRA generally prohibits  
          franchisors from terminating a franchise prior to the expiration  
          of its term, except for good cause.   

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          Last year, AB 2305 (Huffman, 2012) was introduced to enact the  
          Level Playing Field for Small Businesses Act of 2012 and would  
          have amended both the CFIL and CFRA in an attempt to address  
          "the widespread use of one-sided and nonnegotiable franchise  
          agreements [which have] created numerous problems for  
          franchisees in California."  That bill sought to increase  
          protections against unfair practices of franchisors, for  
          example, by permitting termination of a franchise agreement for  
          good cause only where there has been a substantial and material  
          breach of the franchise agreement and the franchisee was granted  
          specified time to cure the breach.  Among other things, the bill  
          would have required good faith in the performance and  
          enforcement of the franchise agreement.  AB 2305 also would have  
          created a cause of action and would have permitted the award of  
          attorney's fees where a franchisor or subfranchisor sold or  
          offered to sell a franchise in violation of the bill's  
          prohibitions against specified unfair or deceptive acts or  
          practices or unfair methods of competition.  

          This bill, is narrower in scope than AB 2305, but similarly  
          amends the CFRA to require franchisors or subfranchisors and  
          franchisees to deal with each other in good faith, as defined.  

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  No   Local:  
           No

          SUPPORT  :   (Verified  4/19/13)

          American Association of Franchisees and Dealers (source)
          C & S Restaurants
          Coalition of Franchise Associations
          Lagarias Law Offices
          Pacific Management Consulting Group 
          Service Station Franchise Association 

           OPPOSITION  :    (Verified  4/19/13)

          California Chamber of Commerce
          California Grocers Association
          California Retailers Association
          Civil Justice Association of California
          International Franchise Association


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           ARGUMENTS IN SUPPORT  :    The American Association of Franchisees  
          and Dealers states that "[m]odern franchise relationships are  
          most always governed by one-sided 'take it or leave it' adhesion  
          contracts that elicit substantial monetary investment from  
          franchise owners, provide substantial protection for  
          franchisors, but severely limit a franchisee's rights in the  
          franchise relationship.  Creating a statutory affirmative duty  
          of good faith in franchise relationships will inhibit the  
          enforcement of one-sided franchise agreements in an abusive  
          manner."

           ARGUMENTS IN OPPOSITION  :    In opposition to this bill, a  
          coalition comprised of the International Franchise Association,  
          California Chamber of Commerce, Civil Justice Association of  
          California, California Grocers Association, and California  
          Retailers Association, raise concerns with the good faith  
          requirement, arguing that it is an "amorphous term?to be applied  
          to the franchisor in its relationship with the franchisee.  The  
          concept of 'good faith' was created in the Uniform Commercial  
          Code to fill in the blanks on short form contracts for the sale  
          of goods.  However, it provides no benefit in the context of  
          detailed franchise contracts which govern complex and ongoing  
          business relationships."


          AL:d  4/19/13   Senate Floor Analyses 

                           SUPPORT/OPPOSITION:  SEE ABOVE

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