Furniture Manufacturers Ass'n v. Grand Rapids Furniture Co.
Docket: Docket No. 1,076
Court: Michigan Court of Appeals; April 25, 1967; Michigan; State Appellate Court
Plaintiffs, two furniture manufacturers and a related association from Grand Rapids, Michigan, filed a lawsuit against defendants, a retail furniture store in Warren, Michigan, alleging unfair competition and common-law trade name infringement. They claimed that the term 'Grand Rapids' in conjunction with 'furniture' constitutes a trade name owned by them, seeking injunctive relief. The trial court found the defendants guilty of unfair competition for misleading the public into believing they had a special association with Grand Rapids and issued an injunction prohibiting the use of 'Grand Rapids' in their business name unless they offered a significant stock of goods manufactured in that area. On appeal, defendants argued that the trial court erred in restricting their use of 'Grand Rapids' and claimed the injunction was vague. The appellate court affirmed the trial court’s decision, referencing the precedent set in Furniture Manufacturers Association of Grand Rapids v. Grand Rapids Guild of Exhibitors, which established 'Grand Rapids Furniture' as a recognized term synonymous with the city’s furniture industry. The court noted that the term has significant public recognition and goodwill, supporting the trial court's finding that its use by the defendants was misleading. The court also highlighted that the statutory prohibition against misleading names applies equally to partnerships as it does to corporations, affirming the trial court's conclusions on unfair competition and the legitimacy of the injunction issued. The trial judge's conclusion that competition exists in the furniture market is supported by the record. Even in the absence of competition, the appellants' actions are prohibited under a specific exception cited in *Good Housekeeping Shop v. Smitter*, which applies to cases where a well-known name, such as Hudson Bay Company, is misused to mislead the public in areas without the company's established presence. The court found no merit in the appellants' claim that the injunction restricts their ability to sell furniture; it only prevents them from using the name 'Grand Rapids' when selling furniture that is not from Grand Rapids. The injunction is deemed appropriate, clear, and unambiguous. Consequently, the trial court's decision is affirmed, and appellees are entitled to recover costs. Judges Quinn and Fitzgerald concurred with the decision.