Brewer v. Exxon Corp.
Plaintiff Brewer filed a lawsuit against Exxon Corporation alleging breach of contract and violations of the Petroleum Marketing Practices Act (PMPA) and Title VII of the 1964 Civil Rights Act. Brewer, an Exxon employee, claimed she was promised a dealership and that her management role was a precondition to an eventual franchise. Exxon later converted the store to a franchise, but Brewer did not acquire it, as it was sold to another individual who was required to purchase two stores. The court analyzed whether the PMPA applied to the relationship between the parties, noting that the Act is intended to cover existing franchise relationships and protect independent dealers who have invested time and money, not preliminary negotiations or mere employees. Finding that Brewer was an employee and did not bear the entrepreneurial risk indicative of a franchisee, the court granted summary judgment to Exxon, dismissing Brewer's claim under the PMPA, while suggesting she might have other common law or statutory remedies.