Justia Antitrust & Trade Regulation Opinion Summaries

Heath and Vail Freyer, the parents of Alicia Freyer, were all riding in their vehicle, which was insured by State Farm, when the vehicle rolled over, causing Health's death. In Freyer I, the Court held that the subject policy provided coverage for Alicia's claim for derivative damages stemming from Health's death. After remand, State Farm paid the disputed coverage amounts. The Freyers then brought claims against State Farm for the wrongful denial of coverage for Alicia's derivative claims. The district court granted summary judgment to State Farm. The Supreme Court reversed in part and affirmed in part, holding that the district court (1) erred in concluding that State Farm had not breached the insurance contract when it failed to indemnify Vail for Alicia's derivative claims based on State Farm's "reasonable basis in law" defense; (2) properly granted summary judgment to State Farm on the common-law bad faith and breach of the covenant of good faith and fair dealing claims; and (3) did not err in granting summary judgment to State Farm on the Unfair Trade Practices Act claims. View "State Farm Mut. Auto. Ins. Co. v. Freyer" on Justia Law

Appellant was in the business of extending high-risk loans to customers with poor credit ratings and operated primarily in Louisiana. Appellees, who resided in Arkansas, obtained four loans from Appellant at its location in Louisiana. After Appellees failed to make payments on the loans, Appellant filed in an Arkansas circuit court a notice of default and intention to sell Appellees' home. Appellees asserted the defenses of usury, unconscionability, esoppel, unclean hands, predatory lending practices, and a violation of the Arkansas Deceptive Trade Practices Act. The circuit court found that the loans constituted predatory lending by a foreign corporation not authorized to do business in Arkansas and that the contract between the parties was unconscionable and could not be given full faith and credit. The Supreme Court affirmed, holding (1) the circuit court's findings of unconscionability and predatory lending practices were not clearly erroneous; and (2) court did not err in refusing to enforce the mortgage, as to do so would contravene the public policy of the State of Arkansas. View "Gulfco of La. Inc. v. Brantley" on Justia Law

Plaintiff obtained a last will and testament from LegalZoom.com. Before receiving the requested document, Plaintiff agreed to LegalZoom.com's terms of service, which included an arbitration provision. The agreement also provided that the Federal Arbitration Act (FAA) governed the interpretation and enforcement of the agreement's provisions. Plaintiff later filed a class-action lawsuit, alleging that LegalZoom.com engaged in the unauthorized practice of law, among other claims. LegalZoom.com filed a motion to compel arbitration. The trial court denied the motion based upon the allegations concerning the unauthorized practice of law. The Supreme Court reversed, holding (1) the circuit court erred because Arkansas law does not prohibit the enforcement of arbitration agreements requiring resolution through arbitration of private claims when a dispute concerns allegations of the unauthorized practice of law; and (2) any rule prohibiting arbitration of unauthorized practice-of-law claims were preempted by the FAA in this case. View "Legalzoom.com, Inc. v. McIllwain" on Justia Law

Suits consolidated under 28 U.S.C. 1407 alleged antitrust violations of price fixing and dividing markets by the manufactures of cooling compressors. The district court dismissed the claims of some of the indirect-buyer plaintiffs and declined to enter a final judgment under Civil Rule 54(b) or to certify an interlocutory appeal under 28 U.S.C. 1292. The Sixth Circuit dismissed an appeal for lack of jurisdiction, concluding that the order did not amount to a “final” decision from which the dismissed plaintiffs may appeal. When a single action involves multiple claims or multiple parties, a ruling that disposes of only some claims or only some parties is ordinarily not “final;” the rule is not different for consolidated multi-district cases. View "In re: Refrigerant Compressors Antitrust Litigation" on Justia Law

Novell, Inc. filed suit against Microsoft Corporation, alleging anti-trust violations. The matter went to trial in 2011, ending in deadlock. The district court concluded Microsoft's conduct did not offend section 2 of the Sherman Act, and entered judgment as a matter of law. Novell appealed to the Tenth Circuit, arguing that Microsoft refused to share its intellectual property with rivals after first promising to do so. The Tenth Circuit concluded after its review that Novell presented no evidence from which a reasonable jury could infer that Microsoft's discontinuation of this arrangement suggested a "willingness to sacrifice short-term profits, […] in a manner that was irrational but for its tendency to harm competition." View "Novell, Inc. v. Microsoft Corporation" on Justia Law

After the Department denied Memorial's application for a Certificate of Need to perform elective percutaneous coronary interventions (PCIs), Memorial filed suit alleging that the PCI regulations were an unreasonable restraint of trade in violation of the Sherman Act, 15 U.S.C. 1, and unreasonably discriminated against interstate commerce in violation of the dormant Commerce Clause and 42 U.S.C. 1983. The court concluded that the requirements did not violate the dormant Commerce Clause where the minimum procedure requirement did not burden interstate commerce and the minimum procedure requirement protected public safety. Accordingly, the court affirmed the district court's dismissal of all of Memorial's remaining claims. View "Yakima Valley Mem'l Hosp. v. Dep't of Health" on Justia Law

This case concerned the 2011 NFL lockout. Active NFL players filed a class action suit (Brady suit) against the NFL, alleging violations of the federal antitrust laws and other claims. Retired NFL players also filed suit against the NFL and its teams, alleging antitrust violations (Eller I suit). After both actions were consolidated, the Brady suit was settled, the players re-designated the NFLPA as their collective bargaining agent, the NFL and NFLPA signed a new collective bargaining agreement (CBA) incorporating the settlement terms, the Brady plaintiffs dismissed their action, the lockout ended, and the 2011 NFL season commenced. Carl Eller and other retired NFL players (plaintiffs) then filed this class action (Eller II) against the NFLPA and others. The district court granted defendants' motion to dismiss and plaintiffs appealed, alleging claims for intentional interference with prospective economic advantage under Minnesota law. The court concluded that no reasonable jury could find that plaintiffs had a reasonable expectation of a prospective separate contractual relation with the NFL that would provide more than the increased benefits provided in the 2011 CBA. Even if plaintiffs alleged a reasonable expectation of prospective contractual relations or economic advantage with the NFL, plaintiffs failed to allege facts proving that defendants improperly or wrongfully interfered with these advantageous prospects. Accordingly, the court affirmed the judgment of the district court. View "Eller, et al. v. NFL Players Assoc., et al." on Justia Law

Credit Bureau Services (CBS) brought an action against Experian Information Solutions (Experian) alleging that Experian sought to drive CBS out of business in violation of Neb. Rev. Stat. 59-805, a provision of Nebraska's antitrust act. After a jury trial, the district court entered judgment in favor of Experian. CBS appealed, and Experian cross-appealed. The Supreme Court affirmed but for different reasoning than that of the district court, holding that the district court erred when it overruled Experian's motion for directed verdict, as CBS failed to prove each element of section 59-805, and therefore, CBS failed to show that Experian engaged in an act of violation of section 59-805.View "Credit Bureau Servs. v. Experian Info. Solutions, Inc." on Justia Law

Groeneveld sued Lubecore, claiming that Lubecore’s automotive grease pump is a “virtually identical” copy of Groeneveld’s automotive grease pump. The complaint asserted tradedress infringement in violation of section 43(a) of the Lanham Act, 15 U.S.C. 1125(a), and violation of related federal and Ohio laws. The trade-dress claim went to the jury, which found for Groeneveld and awarded it $1,225,000 in damages. The Sixth Circuit reversed, holding that a company cannot use trade-dress law to protect its functional product design from competition with a “copycat” design made by another company where there is no reasonable likelihood that consumers would confuse the two companies’ products as emanating from a single source. Trademark law is designed to promote brand recognition, not to insulate product manufacturers from lawful competition. View "Groeneveld Transp. Efficiency, Inc. v. Lubecore Int'l, Inc." on Justia Law

Employees of Michaels Stores, Inc. request and record customers' zip codes in processing credit card transactions. Plaintiff, a customer of Michaels, filed an action on behalf of herself and a putative class of Michaels customers in the federal district court, alleging that Michaels unlawfully writes customers' personal identification information on credit card transaction forms in violation of Mass. Gen. Laws ch. 93, 105(a) (the statute). The Supreme Court accepted certification to answer questions of state law and held (1) a zip code constitutes personal identification information for purposes of the statute; (2) a plaintiff may bring an action for violation of the statute absent identity fraud; and (3) the term "credit card transaction form" in the statute refers equally to electronic and paper transaction forms.View "Tyler v. Michael Stores, Inc." on Justia Law