JRS Products, Inc. v. Matsushita Electric Corp. of America

A franchisor that wrongfully terminates a franchise is liable to the franchisee for breach of contract, not for intentional interference with prospective economic advantage. In this case, the franchisee’s first cause of action against the franchisor was, in fact, predicated on a breach of contract theory, but the trial court erroneously granted a summary adjudication of that claim. After we dismissed the franchisee’s appeal on the contract claim as an appeal from a nonfinal judgment, the franchisee was compelled to try the case solely on a tort theory and prevailed. We reverse the ensuing judgment because, as the franchisor argues on appeal, its conduct, though wrongful, consisted exclusively of breaching the contract. We also reverse the judgment dismissing the contract claim because, as the franchisee argues in the cross-appeal, the California Franchise Relations Act (Act; Bus. & Prof. Code, § 20000 et seq.) does not bar a franchisee from recovering damages for breach of contract.

FACTS

Plaintiff JRS Products, Inc. (JRS), objects to defendant Panasonic’s concise summary of the facts, insisting that a detailed chronology of Panasonic’s wrongdoing is essential to…