Allapattah Services, Inc. v. Exxon Corporation

61 F. Supp. 2d 1326 (1999)

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Allapattah Services, Inc. v. Exxon Corporation

United States District Court for the Southern District of Florida
61 F. Supp. 2d 1326 (1999)

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Facts

Exxon Corporation (defendant) sold gasoline to fuel dealers according to a pricing model specified in supply contracts. Allapattah Services, Inc., and roughly 10,000 other fuel dealers (collectively, the dealers) (plaintiffs) claimed that Exxon had systematically overcharged them in breach of these contracts. The dealers brought a class-action lawsuit in federal district court, alleging breach-of-contract claims under the Uniform Commercial Code (UCC). Shortly before the trial, the dealers moved to add a request for punitive damages. The dealers’ basis for the punitive damages was an allegation that Exxon had breached the contracts in bad faith. Exxon objected that (1) punitive damages were inappropriate in a UCC breach-of-contract case with no independent tort claims, (2) adding state-law tort claims to this multi-state class action would be inappropriate, and (3) the motion was untimely.

Rule of Law

Issue

Holding and Reasoning (Gold, J.)

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