Marks v. Shell Oil Company, 643 F. Supp. 1050 (E.D. Mich. 9-17-86); vac'd and rem'd, 830 F.2d 68 (6th Cir. 10-2-87)

Appellate court vacated and remanded summary judgment for franchisor for the reason that the district court abused its discretion in not franchisee's motion to amend her complaint. Her original complaint was for nonrenewal upon expiration of the underlying lease. The district court held that franchisor's knowledge more than 120 days before that it would not renew the underlying lease did not render the nonrenewal impermissible.