The Connecticut Appellate Court held that convenience store operators who dispensed fuel as commissioned agents were not “retailers” under the Connecticut Petroleum Franchise Act (CPFA). Branford Quick Mart, LLC v. Aldin Assocs. Ltd. P’ship, 2026 WL 207302 (Conn. App. Ct. Jan. 27, 2026).
The plaintiffs leased convenience stores from defendant Aldin Associates that were adjacent to fuel pumps owned, stocked, branded, and controlled by Aldin. Aldin retained ownership of the motor fuel from delivery until it entered a customer’s tank, set all retail prices, owned and maintained the tanks and dispensing equipment, and collected all proceeds from fuel sales—paying the plaintiffs only a per‑gallon commission. When Aldin terminated the convenience store leases without cause, the plaintiffs claimed the terminations violated the CPFA because they were “retailers” and therefore “franchisees” entitled to CPFA protections, and the terminations lacked good cause. The trial court disagreed and entered judgment for Aldin, and the plaintiffs appealed.
The appellate court affirmed. It concluded that Aldin, not the plaintiffs, was the actual retailer of the motor fuel because it owned the fuel, controlled pricing, bore the risk of loss, and held the necessary fuel retailing licenses. Because the CPFA applies only to contracts involving retailers, the relationship fell outside the statute. Thus, the plaintiffs were “agents of the seller,” not sellers themselves. The court also rejected plaintiffs’ contention that the arrangement converted the relationship into a consignment that would place them within the CPFA. There was no true consignment because the plaintiffs’ responsibilities merely facilitated Aldin’s retail sales; the fuel remained in the custody, control, and possession of Aldin until sale.
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