Indiana Code

Ind. Code § 23-2-2.7-1 (2026)

Franchise agreement; unlawful provisions

✓ current as of May 2026
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     Sec. 1. It is unlawful for any franchise agreement entered into between any franchisor and a franchisee who is either a resident of Indiana or a nonresident who will be operating a franchise in Indiana to contain any of the following provisions:

(1) Requiring goods, supplies, inventories, or services to be purchased exclusively from the franchisor or sources designated by the franchisor where such goods, supplies, inventories, or services of comparable quality are available from sources other than those designated by the franchisor. However, the publication by the franchisor of a list of approved suppliers of goods, supplies, inventories, or service or the requirement that such goods, supplies, inventories, or services comply with specifications and standards prescribed by the franchisor does not constitute designation of a source nor does a reasonable right of the franchisor to disapprove a supplier constitute a designation. This subdivision does not apply to the principal goods, supplies, inventories, or services manufactured or trademarked by the franchisor.

(2) Allowing the franchisor to establish a franchisor-owned outlet engaged in a substantially identical business to that of the franchisee within the exclusive territory granted the franchisee by the franchise agreement; or, if no exclusive territory is designated, permitting the franchisor to compete unfairly with the franchisee within a reasonable area.

(3) Allowing substantial modification of the franchise agreement by the franchisor without the consent in writing of the franchisee.

(4) Allowing the franchisor to obtain money, goods, services, or any other benefit from any other person with whom the franchisee does business, on account of, or in relation to, the transaction between the franchisee and the other person, other than for compensation for services rendered by the franchisor, unless the benefit is promptly accounted for, and transmitted to the franchisee.

(5) Requiring the franchisee to prospectively assent to a release, assignment, novation, waiver, or estoppel which purports to relieve any person from liability to be imposed by this chapter or requiring any controversy between the franchisee and the franchisor to be referred to any person, if referral would be binding on the franchisee. This subdivision does not apply to arbitration before an independent arbitrator.

(6) Allowing for an increase in prices of goods provided by the franchisor which the franchisee had ordered for private retail consumers prior to the franchisee's receipt of an official price increase notification. A sales contract signed by a private retail consumer shall constitute evidence of each order. Price changes applicable to new models of a product at the time of introduction of such new models shall not be considered a price increase. Price increases caused by conformity to a state or federal law, or the revaluation of the United States dollar in the case of foreign-made goods, are not subject to this subdivision.

(7) Permitting unilateral termination of the franchise if such termination is without good cause or in bad faith. Good cause within the meaning of this subdivision includes any material violation of the franchise agreement.

(8) Permitting the franchisor to fail to renew a franchise without good cause or in bad faith. This chapter shall not prohibit a franchise agreement from providing that the agreement is not renewable upon expiration or that the agreement is renewable if the franchisee meets certain conditions specified in the agreement.

(9) Requiring a franchisee to covenant not to compete with the franchisor for a period longer than three (3) years or in an area greater than the exclusive area granted by the franchise agreement or, in absence of such a provision in the agreement, an area of reasonable size, upon termination of or failure to renew the franchise.

(10) Limiting litigation brought for breach of the agreement in any manner whatsoever.

(11) Requiring the franchisee to participate in any:

(A) advertising campaign or contest;

(B) promotional campaign;

(C) promotional materials; or

(D) display decorations or materials;

at an expense to the franchisee that is indeterminate, determined by a third party, or determined by a formula, unless the franchise agreement specifies the maximum percentage of gross monthly sales or the maximum absolute sum that the franchisee may be required to pay.

As added by Acts 1976, P.L.116, SEC.1. Amended by P.L.233-1985, SEC.5; P.L.11-1987, SEC.27.

 

Notes of Decisions
Cited in 27 cases, 1977–2018 · leading case: Wright-Moore Corp., Cross-Appellee v. Ricoh Corp., Cross-Appellant, 908 F.2d 128 (7th Cir. 1990).
Wright-Moore Corp., Cross-Appellee v. Ricoh Corp., Cross-Appellant, 908 F.2d 128 (7th Cir. 1990). · cites it 8× “” Ind.Code § 23-2-2.7-1(10). Ri-coh argues that the express choice of law provision of the contract should govern.”
Dersch Energies, Inc. v. Shell Oil Co. & Equilon Enter., Inc., 314 F.3d 846 (7th Cir. 2002). · cites it 3× “While I am inclined to believe that the effect of Article 5 is to allow a “substantial modification of the franchise agreement” without written consent of Dersch, there has been insufficient factual development to determine whether, in fact, Dersch qualifies for the protection…”
Implement Serv., Inc. v. Tecumseh Prods. Co., 726 F. Supp. 1171 (S.D. Ind. 1989). · cites it 5× “The plaintiff alleges that this clause violates Ind.Code Ann. § 23-2-2.7-1, which, in part, reads as follows: It is unlawful for any franchise agreement entered into between any franchisor and a franchisee who is either a resident of Indiana or a non-resident who will be…”
Cont'l Basketball Ass'n v. Ellenstein Enter., Inc., 669 N.E.2d 134 (Ind. 1996). · cites it 2× “7-1(7), or that permits a franchisor to fail to renew a franchise without good cause or in bad faith, Ind.Code § 23-2-2.7-1(8) 8 Section 23-2-2.”
Canada Dry Corp. v. Nehi Beverage Co., Inc. Of Indianapolis, 723 F.2d 512 (7th Cir. 1983). · cites it 2× “The verdicts appealed by Canada *515 Dry are for breaches of contract, illegal discrimination among franchisees in violation of the Indiana Deceptive Franchise Practices Act, Ind.Code § 23-2-2.7-1, et seq. (1976), and for compensatory and punitive damages.”
Wright-Moore Corp. v. Ricoh Corp., 794 F. Supp. 844 (N.D. Ind. 1991). · cites it 6× “Code § 23-2-2.7-1, as alleged, the Indiana act was not intended to have extraterritorial effect and thus was not intended to protect the “national” distributorship relationship established between Wright-Moore and Ricoh under the Distributorship Agreement.”
Monroe Cnty. Oil Co., Inc. v. Amoco Oil Co., 75 B.R. 158 (S.D. Ind. 1987). · cites it 2× “Count X — Alleges violation of Ind.Code § 23-2-2.7-1(3) (Indiana Deceptive Franchise Practices Act) by the inclusion of a provision in the Jobber Contract which allows the unilateral modification of credit terms.”
Hubbard Auto Ctr., Inc. v. Gen. Motors Corp., 422 F. Supp. 2d 999 (N.D. Ind. 2006). · cites it 7× “Indiana Franchise Statutes Hubbard contends that GM violated Indiana Code § 23-2-2.7-1(7) and (8) by terminating Hubbard’s Oldsmobile franchise without good cause or in bad faith.”
D. Patrick, Inc., an Indiana Corp. v. Ford Motor Co., a Delaware Corp., 8 F.3d 455 (7th Cir. 1993). “§§ 1221-1225 , and the Indiana Deceptive Franchise Practices Act, Ind.Code §§ 23-2-2.7-1 et seq., and Motor Vehicle Unfair Practices Act, 9-23-3-1 et seq.”
Gre-Ter Enters., Inc. v. Mgmt. Recruiters Int'l, Inc., 329 F. Supp. 3d 667 (S.D. Ind. 2018). · cites it 2× “§ 23-2-2.7-1 (prohibited provisions of franchise *681 agreement); id.”
Sullivan v. Savin Bus. MacHines Corp., 560 F. Supp. 938 (N.D. Ind. 1983). · cites it 2× “1982), and is therefore in violation of the Indiana Deceptive Franchise Practices Act, Ind.Code § 23-2-2.7-1 et seq. (Burns Ann.”
Steve Montgomery, James N. Fash & Donald R. Hall v. Amoco Oil Co., 804 F.2d 1000 (7th Cir. 1986). · cites it 3× “The appellants are Indiana dealers who allege that the fee on credit sales under DFC violates both the existing credit card agreement between Amoco and its dealers and the Indiana Deceptive Franchise Practices Act, Ind.Code §§ 23-2-2.7-1 to 23-2-2.7-7 (1976) (IDFPA).”
Ind. Code § 23-2-2.7-1(10): 5 cases
Wright-Moore Corp., Cross-Appellee v. Ricoh Corp., Cross-Appellant, 908 F.2d 128 (7th Cir. 1990). “” Ind.Code § 23-2-2.7-1(10). Ri-coh argues that the express choice of law provision of the contract should govern.”
Gre-Ter Enters., Inc. v. Mgmt. Recruiters Int'l, Inc., 329 F. Supp. 3d 667 (S.D. Ind. 2018). “§ 23-2-2.7-1 (prohibited provisions of franchise *681 agreement); id.”
Banek Inc. v. Yogurt Ventures U.S.A., Inc., 6 F.3d 357 (6th Cir. 1993).
Flynn Beverage Inc. v. Joseph E. Seagram & Sons, Inc., 815 F. Supp. 1174 (C.D. Ill. 1993).
Kinnard v. Shoney's, Inc., 39 F. App'x 313 (6th Cir. 2002).
Ind. Code § 23-2-2.7-1(11): 2 cases
Anderson v. Indianapolis Indiana AAMCO Dealers Advert. Pool, 678 N.E.2d 832 (Ind. Ct. App. 1997).
Ind. Code § 23-2-2.7-1(3): 5 cases
Dersch Energies, Inc. v. Shell Oil Co. & Equilon Enter., Inc., 314 F.3d 846 (7th Cir. 2002). “While I am inclined to believe that the effect of Article 5 is to allow a “substantial modification of the franchise agreement” without written consent of Dersch, there has been insufficient factual development to determine whether, in fact, Dersch qualifies for the protection…”
Monroe Cnty. Oil Co., Inc. v. Amoco Oil Co., 75 B.R. 158 (S.D. Ind. 1987). “Count X — Alleges violation of Ind.Code § 23-2-2.7-1(3) (Indiana Deceptive Franchise Practices Act) by the inclusion of a provision in the Jobber Contract which allows the unilateral modification of credit terms.”
Wright-Moore Corp., Cross-Appellee v. Ricoh Corp., Cross-Appellant, 908 F.2d 128 (7th Cir. 1990). “” Ind.Code § 23-2-2.7-1(10). Ri-coh argues that the express choice of law provision of the contract should govern.”
Wright-Moore Corp. v. Ricoh Corp., 794 F. Supp. 844 (N.D. Ind. 1991). “Code § 23-2-2.7-1, as alleged, the Indiana act was not intended to have extraterritorial effect and thus was not intended to protect the “national” distributorship relationship established between Wright-Moore and Ricoh under the Distributorship Agreement.”
Steve Montgomery, James N. Fash & Donald R. Hall v. Amoco Oil Co., 804 F.2d 1000 (7th Cir. 1986). “The appellants are Indiana dealers who allege that the fee on credit sales under DFC violates both the existing credit card agreement between Amoco and its dealers and the Indiana Deceptive Franchise Practices Act, Ind.Code §§ 23-2-2.7-1 to 23-2-2.7-7 (1976) (IDFPA).”
Ind. Code § 23-2-2.7-1(5): 3 cases
Elec. & Magneto Serv. Co. v. AMBAC Int'l Corp., 745 F. Supp. 1501 (W.D. Mo. 1990).
Deans v. Tutor Time Child Care Sys., Inc., 982 F. Supp. 1330 (S.D. Ind. 1997).
Kinnard v. Shoney's, Inc., 39 F. App'x 313 (6th Cir. 2002).
Ind. Code § 23-2-2.7-1(7): 7 cases
Wright-Moore Corp., Cross-Appellee v. Ricoh Corp., Cross-Appellant, 908 F.2d 128 (7th Cir. 1990). “” Ind.Code § 23-2-2.7-1(10). Ri-coh argues that the express choice of law provision of the contract should govern.”
Hubbard Auto Ctr., Inc. v. Gen. Motors Corp., 422 F. Supp. 2d 999 (N.D. Ind. 2006). “Indiana Franchise Statutes Hubbard contends that GM violated Indiana Code § 23-2-2.7-1(7) and (8) by terminating Hubbard’s Oldsmobile franchise without good cause or in bad faith.”
Wright-Moore Corp. v. Ricoh Corp., 794 F. Supp. 844 (N.D. Ind. 1991). “Code § 23-2-2.7-1, as alleged, the Indiana act was not intended to have extraterritorial effect and thus was not intended to protect the “national” distributorship relationship established between Wright-Moore and Ricoh under the Distributorship Agreement.”
Ind. Code § 23-2-2.7-1(8): 2 cases
Cont'l Basketball Ass'n v. Ellenstein Enter., Inc., 669 N.E.2d 134 (Ind. 1996). “7-1(7), or that permits a franchisor to fail to renew a franchise without good cause or in bad faith, Ind.Code § 23-2-2.7-1(8) 8 Section 23-2-2.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.