Articles Posted in US Court of Appeals for the Eleventh Circuit

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The Body Shops filed suit alleging that defendant insurance companies colluded to lower repair prices by improperly pressuring the shops to lower prices and by threatening to boycott those who did not comply. The Body Shops claimed a per se price-fixing conspiracy and a per se conspiracy to boycott, as well as state law claims. The Eleventh Circuit affirmed the district court's dismissal of all of the Body Shop's federal antitrust and state law claims except the tortious interference claims. Although the court held that the unjust enrichment and quantum meruit claims of the Body Shops were wholly without merit, the court vacated the district court's judgment as to the tortious interference claims because the court was not persuaded by the district court's grounds for concluding that the allegations of tortious interference in each of these five cases violated the group pleading doctrine, i.e., failed to give fair notice to each defendant of the claim being made against it. The court remanded for further proceedings. View "Quality Auto Painting Center of Roselle, Inc. v. State Farm Indemnity Co." on Justia Law

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The Eleventh Circuit reversed the dismissal of five complaints filed by automobile body shops, asserting federal antitrust and state tort claims against insurance companies. The court held that the shops pleaded enough facts to plausibly support their federal antitrust and state tort claims. In this case, the body shops argued that the insurance companies engaged in two lines of tactics in pursuit of a single goal: to depress the shops' rates for automobile repair. The body shops have supplied enough allegations to raise a reasonable expectation that discovery will reveal evidence of an illegal agreement; the body shops have consistently alleged the existence of parallel conduct and of plus factors allowing a plausible inference of an illegal agreement; and the allegations have sufficiently established the body shops' state tort claims of unjust enrichment, quantum meruit, and tortious interference. Accordingly, the court remanded for further proceedings. View "Quality Auto Painting Center of Roselle, Inc. v. State Farm Indemnity Co." on Justia Law