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Winn-Dixie Stores, Inc., Et Alv.Dolgencorp, Llc, Et Al

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.15-12990
DecidedJanuary 31, 2018
JudgesUnited States Court of Appeals for the Eleventh Circuit
Tags
CivilBusiness LawContract LawContract InterpretationProperty LawReversalRemand
Case Summary

Winn-Dixie challenged competing stores’ use of leased property, arguing that its grocery-store leases gave it exclusive rights to sell groceries in specified sales areas. The Eleventh Circuit reviewed consolidated appeals involving stores in Florida and Alabama and addressed how the leases defined those terms. For the Florida stores with older leases, the court held that the district court had applied the wrong definitions when deciding whether Dollar General and Big Lots violated the exclusivity provisions. It directed the district court to apply the same definitions it had used for later Florida leases, under which sales area included fixtures and proportionate aisle space and groceries included food, beverages, and certain household supplies. The court reached a different conclusion for the Alabama stores because Alabama law lacked binding authority adopting the narrower interpretation and the relevant terms were reasonably ambiguous. The ambiguity therefore had to be resolved against Winn-Dixie. The court reversed and remanded as to the Florida stores and affirmed as to the Alabama stores.

Opinion

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Winn-Dixie Stores, Inc., Et Al V. Dolgencorp, Llc, Et Al — The Atlanta Gleaner