Nissan N. Am., Inc. v. Wayzata Nissan, LLC, No. 14-2971 (8th Cir. 2015)Annotate this Case
Eighteen years after Nissan and Wayzata entered into an agreement which established Wayzata as an authorized Nissan dealer, Nissan informed Wayzata that it intended to establish a new dealership in Eden Prairie, eight miles from Wayzata. Nissan sought a declaratory judgment that the Eden Prairie dealership neither violated their dealer agreement nor infringed Wayzata's "relevant market area" under Minn. Stat. 80E.14. One month later, Wayzata sued Nissan in Minnesota state court, alleging the new dealership violated its dealer agreement and the statute, and moved to dismiss the federal action for lack of subject matter jurisdiction. The district court granted the motion to dismiss after concluding that the parties were not diverse under 28 U.S.C. 1332. The Eighth Circuit affirmed. A district court may dismiss or stay a declaratory judgment action when it determines that the question in controversy would be better handled in state court. It would be duplicative and uneconomical for a federal court to decide a case substantially similar to one which has been pending for over a year in state court.