Foley Secures First Circuit Victory for Daimler Truck North America in Dormant Commerce Clause Dealer Law Appeal

Decision reinforces constitutional limits on state dealer laws and provides important guidance for suppliers, manufacturers, and distributors operating across state lines

Foley & Lardner LLP represented Daimler Truck North America LLC (DTNA) in a significant victory before the U.S. Court of Appeals for the First Circuit in Rhode Island Truck Center, LLC v. Daimler Trucks North America, LLC.

Rhode Island Truck Center LLC (RITC) had protested under Rhode Island’s motor vehicle dealer protection law, alleging that DTNA violated the statute by appointing a Freightliner dealer in neighboring Massachusetts within RITC’s contractual territory. RITC sought an order requiring DTNA to remove the Massachusetts dealership.

The First Circuit agreed with Foley’s argument that Rhode Island could not constitutionally enforce its dealer statute to regulate DTNA’s out-of-state dealership appointment. In its opinion issued July 6, 2026, the court held that such enforcement would violate the Dormant Commerce Clause by directly regulating an out-of-state transaction and potentially exposing DTNA to inconsistent state regulatory obligations. The decision distinguished Rhode Island’s law from statutes with a sufficiently strong in-state nexus, finding that the enforcement sought by RITC impermissibly implicated out-of-state commerce, competition, and dealership operations.

The ruling is particularly significant for suppliers, manufacturers, and distributors whose sales territories, dealer networks, or franchise relationships cross state lines. It provides meaningful guidance on the constitutional limits of state dealer statutes when those laws are invoked to restrict business and operational decisions in another state.

Foley’s appellate litigation team was led by partner Nathan Imfeld.