A Rhode Island District Court judge has remanded a federal antitrust lawsuit against Jaguar North America (JaguarNA) to state court.

An Oct. 16 order states that Providence Auto Body (PAB) alleges JaguarNA violated Rhode Island antitrust laws by “only allowing one automobile repair facility to be certified.”

JaguarNA requires collision repair facilities to be nominated for certification by a shop within its network and only distributes OEM structural and safety parts to certified network facilities, according to court documents.

In a 2019 letter, PAB’s attorney requested that the owner of Jake Kaplan’s Ltd. and Land Rover Warwick (Jake Kaplan) sponsor PAB to become part of the collision repair network.

“Jake Kaplan’s owner testified that she was ‘really upset’ by PAB’s attorney’s letter, which she found ‘unsettling,’ so she did not respond to the letter,” according to background information given in the District Court’s order. “Jake Kaplan has never refused to nominate PAB to participate in JaguarNA’s authorized collision repair network. PAB did not request sponsorship from any other Jaguar or Land Rover dealer. There is no evidence that JaguarNA interfered with the nomination process.”

PAB seeks an injunction from the court that would allow it to apply for repair certification under JaguarNA’s current program. PAB filed its complaint in state court and JaguarNA removed it to federal court.

JaguarNA alleges PAB lacks standing because the “injury it suffered resulted not from [JaguarNA’s] conduct and is, thus, not redressable” by the court.

PAB contends that the “illegal tie is between the sale of structural parts vis a vie [JaguarNA’s] manufacture and sale of automobiles to its restricted repair certification program.”

Because JaguarNA is the party that invoked federal jurisdiction, it bore the burden of proving constitutionally sufficient standing in federal court.

To have standing, it must be proven that there is actual or imminent injury-in-fact, a causal connection between the alleged action and identified harm, and redressability that would likely alleviate harm from the injury.

The court found no recorded evidence that JaguarNA prevented PAB or any other repair facility from applying for certification.

Based on precedent, “decisions by third parties break the chain of causation between an injury and challenged actions,” Chief Judge John. J. McConnell Jr. noted in his order. He also determined there is no evidence of a “coercive effect” wherein JaguarNA coerced the third party, Jake Kaplan, in any way.

Lastly, the court ruled that PAB’s requested relief isn’t redressable in a federal lawsuit because it can already seek JaguarNA certification leaving no alleged injury to redress.

Because PAB seeks relief from a third party and the claims aren’t redressable in federal court, McConnell remanded the case to state court. In doing so, JaguarNA’s motion for summary judgment was granted.

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