Text of the decision: http://www.mass.gov/courts/docs/sjc/reporter-of-decisions/ne...

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Edit: having read the decision, I thought it might be fun to explain what the Court did here. Reading statutes is a lot like reading code. Reading cases is like ... not running the code, because we can't do that, but more like having it explained by a particularly skillful coder with decades of experience. It's fascinating if you're into that stuff.

So to start with, we have this statute in Massachusetts that says it is unlawful for a car manufacturer "to own or operate, either directly or indirectly through any subsidiary, parent company or firm, a motor vehicle dealership located in the commonwealth of the same line make as any of the vehicles manufactured ... by the manufacturer[.]"

Sounds pretty clear cut, right? Tesla can't run a dealership in Massachusetts that sells Teslas -- there's no helpful exception left out of that quote. But the Court didn't come out that way.

If you really want the reading-unfamiliar-code experience, go read the surrounding parts of the statute[1] and see how you think the Court understood that section. It's under subsection (10).

...

So, it turns out the Court looked to the legislative history, which is the closest we have to comments -- statements of legislators and the Governor explaining why they were voting for (or not vetoing) the statute. (As a side note, Massachusetts has terrible legislative history, because not much was recorded of the debates, many decisions are made behind closed doors by the Democratic super-majority, and unlike Congress, we rarely explain why a statute is being passed in the text itself -- but there seems to be some history in this case.) The Court concluded that the statute is intended to protect dealers from their own manufacturers. The Court finds: "the purpose of c.93B historically was to protect motor vehicle dealers from a host of unfair acts and practices historically directed at them by their own brand manufacturers and distributors." Or, quoting an earlier case, it's about "preserving a sound competitive market free of the domination of oligopolists[.]"

That matters because intent matters -- the Court isn't a computer, and if at all possible it tries to do what the Legislature actually wanted.

So then the Court looks back at the statute, and lo and behold, subsection 10 is only one of 12 subsections! (We knew there had to be at least 10.) And every single one of them (besides #10) is obviously designed to regulate relationships between dealers and their own manufacturers. So the Court says, "It would be anomalous to find, within this detailed list of rights and protections that are conferred on dealers vis-à-vis their manufacturers and distributors, a lone provision giving dealers protection against competition from an unaffiliated manufacturer." Instead, they conclude that the Legislature -- which was trying to promote competition -- must have intended subsection 10, like the others, to be a right of dealers against their own manufacturers.

And that's why this is ultimately dismissed on the basis of "standing." Cases (almost always) have to be filed by someone with a legally protected interest at stake. If the statute is designed to protect Tesla dealers (if any), then only Tesla dealers can file a case. That means, for now, no one can.

(It's an interesting side effect that this essentially means there can be no third-party Tesla dealers in Massachusetts as long as Tesla is selling directly. It's an open question whether that's a good thing.)

[1] https://malegislature.gov/Laws/GeneralLaws/PartI/TitleXV/Cha...