Justia Antitrust & Trade Regulation Opinion Summaries

Plaintiffs alleged that they purchased billions of dollars worth of mobile handsets containing defendants' LCD panels and that the prices they paid for those handsets were artificially inflated because defendants had orchestrated a global conspiracy to fix the prices of LCD panels. The district court certified to the court pursuant to 28 U.S.C. 1292(b) "the question whether the application of California antitrust law to claims against defendants based on purchases that occurred outside California would violate the Due Process Clause of the United States Constitution." Because the underlying conduct in this case involved not just the indirect purchase of price-fixed goods, but also the conspiratorial conduct that led to the sale of those goods, the court answered in the negative. To the extent a defendant's conspiratorial conduct was sufficiently connected to California, and was not "slight and casual," the application of California law to that conduct was "neither arbitrary nor fundamentally unfair," and the application of California law did not violate that defendant's rights under the Due Process Clause. Therefore, the court reversed the district court's order dismissing plaintiffs' California law claims and remanded for further proceedings.View "AT&T Mobility LLC, et al v. AU Optronics Corp., et al" on Justia Law

This case involved an alleged bid-rigging scheme that sought to defraud various New York State and City government agencies in connection with the purchase by those agencies of a particular brand of mobile radio. Gatt, an admitted past participant in the purported scheme, sought to recover damages from alleged co-conspirators for losses arising from the termination of Gatt's at-will distribution contract for those radios. Gatt raised federal and state antitrust claims arising under the Sherman Act, 15 U.S.C. 1; the Donnelly Act, N.Y. Gen. Bus. Law 340; and New York common law. The court concluded that Gatt lacked antitrust standing to pursue its antitrust claims and that its common law claims were properly dismissed as a matter of law. Therefore, the court affirmed the district court's dismissal of Gatt's complaint.View "Gatt Communications, Inc. v. PMC Associates, L.L.C." on Justia Law

Leonard Landa was the sole managing member of a Montana limited liability corporation. Landa carried commercial general liability insurance through Assurance. After a former employee of Landa's filed a complaint alleging that Landa had committed various torts by inducing him to work for Landa under allegedly false pretenses, Landa tendered defense of the former employee's claim to Assurance. Assurance refused to defend Landa, stating that the complaint's allegations were not covered under Landa's policy. Landa filed a complaint seeking declaratory relief establishing that Assurance had a duty to defend and indemnify Landa and alleging violations of Montana's Unfair Trade Practices Act (UTPA), negligence, and other causes of action. The district court granted summary judgment for Assurance, finding that the complaint's allegations were not covered under Landa's policy and that Assurance was not liable under the UTPA because the denial of coverage was grounded on a legal conclusion. The Supreme Court affirmed, holding that Assurance correctly declined to provide a defense where the former employee's complaint did not allege an "occurrence" and, as a result, did not trigger a duty to defend under the policy. View "Landa v. Assurance Co. of Am." on Justia Law

KME and GTT are competitors in the specialized market for devices that permit emergency vehicles to send a signal that preempts traffic lights and allows the vehicle to pass through an intersection with, rather than against, the light. One system relies on optical signals and one uses GPS signals. GTT’s optical products are called “Opticom.” In 2010, GTT filed a patent infringement suit against KME; KME filed a separate suit against GTT. In 2011, KME twice sued, challenging the New York Department of Transportation’s award of traffic‐preemption contracts to GTT vendors. In 2012 KME sued, alleging that GTT violated antitrust laws by improperly interfering with competitive bidding on public contracts and engaging in monopolistic activity similar to illegal tying, claiming that GTT improperly persuades agencies to specify Opticom technology when drafting public contract requirements and then falsely informs those agencies that Opticom is no longer available and offers to supply a “dual” unit with both optical and GPS technology. The district court dismissed for improper venue, reasoning that GTT did not reside in the district and that none of the events at issue took place there. The Seventh Circuit affirmed, after exploring the “surprisingly complex” relation between general principles of personal jurisdiction and venue and the Clayton Act’s special jurisdiction and venue provisions. View "KM Enters. Inc. v. Global Traffic Techs., Inc." on Justia Law

In 2003, Plaintiffs filed a complaint against a police officer and city, alleging that, in 1999, the officer entered Plaintiffs' convenience store, arrested two of the plaintiffs, and beat all of the plaintiffs. Two of the plaintiffs were acquitted of criminal charges, but, in the meantime, Plaintiffs lost their business and suffered physical and emotional injuries. More than thirteen years after the incident and after a "tortuous" procedural history, the case arrived at the Supreme Court on limited further appellate review. In Jones II, the appeals court ordered the reinstatement of a 2004 default judgment against Defendants. The Court also had before it on direct appellate review an order of the superior court that amended the 2004 default judgment to correct a clerical error and that reinstated it. The Supreme Court (1) vacated the default judgment and remanded the matter for further proceedings to assess damages, holding that, under the circumstances here, a remand was necessary; and (2) vacated the amended judgment, holding that the superior court did not have jurisdiction to entertain a motion to amend the earlier default judgment, even to correct a clerical mistake, at the time the motion judge acted in 2012.View "Jones v. Boykan" on Justia Law

Petitioner filed a complaint against Respondent for unfair and deceptive trade practices and for common law fraud. Petitioner's complaint was based on an automobile warranty he purchased from Respondent that expired more than two years earlier than he had been led to believe. Petitioner purported to bring his action on behalf of others similarly situated. Before Petitioner filed a motion to certify the class, however, Respondent paid to extend Petitioner's warranty. The circuit court (1) denied Petitioner's motion for class certification, finding that because he had been made whole, Petitioner was no longer a member of any class; (2) granted in part Respondent's motion for summary judgment, finding Petitioner's claim moot; and (3) granted Petitioner attorney's fees for the period before and after Respondent tendered Petitioner individual relief. The Court of Appeals affirmed in part and reversed in part, holding (1) Respondent's tender of individual compensatory relief to Petitioner did not require the court to deny class certification; (2) an award of punitive damages is not foreclosed by the tender of individual compensatory damages; and (3) an award of attorney's fees to Petitioner under a fee-shifting provision of the Consumer Protection Act is not limited to fees incurred before the tender. View "Frazier v. Castle Ford, Ltd." on Justia Law

Gorlick sued Allied, a competitor in the auto parts market, alleging that Allied was receiving favorable prices from a manufacturer. The court concluded that Gorlick failed to show that Allied had actual knowledge, trade knowledge or a duty to inquire whether the favorable prices it received might be prohibited by the Robinson-Patman Act, 15 U.S.C. 13(f). The court also concluded that Gorlick failed to provide a plausible explanation for how the alleged agreement between a manufacturer and a distributor, concerning a product line without market dominance, caused harm to competition in the entire automotive exhaust product market. Even assuming that a vertical agreement existed and that it affected the price of the products at issue, there's no plausible showing of harm to competition in the market for automotive exhaust products as a whole. Therefore, the court concluded that Gorlick's claim under the Sherman Act, 15 U.S.C. 1, failed as a matter of law. Accordingly, the court affirmed the district court's grant of summary judgment in favor of Allied. View "Gorlick Distrib. Ctrs. v. Car Sound Exhaust Sys." on Justia Law

In this antitrust case, GSRG challenged the district court's grant of summary judgment in favor of Nucor. The court affirmed, concluding that GSRG's definition of the product market was too restrictive, for it refused to acknowledge that pickled and oiled steel manufacturers could enter the fray in order to enrich themselves on the inflated prices of black hot rolled coil steel. That would, in turn, increase the supply, and lower the price, of black hot rolled coil steel. It would also sap Nucor's potential monopoly over power. GSRG ignored this "actual or potential" economic construct, and its failure to account for cross-elasticity of supply was fatal to the attempted monopolization claim under the Sherman Act, 15 U.S.C. 2. View "Gulf States Reorganization Group, Inc. v. Nucor Corp." on Justia Law

Prime Motor Cars sold Seacoast RV, Inc. a car. The car had modifications that voided the manufacturer's warranty and caused mechanical problems that may not have been apparent when the car was sold because the "check engine" light was covered with opaque tape. Seacoast filed a complaint against Prime, alleging breach of contract, breach of warranty, fraud, violation of the Maine Unfair Trade Practices Act (UTPA), and punitive damages. The district court granted Prime's motion for judgment as a matter of law on the UTPA and punitive damages claims. The court then concluded that Prime's conduct constituted breach of contract and breach of warranty, but found against Seacoast on the fraud claim. The court rescinded the contract and ordered Prime to refund Seacoast and Seacoast to return the vehicle to Prime. The Supreme Court affirmed, holding that the district court did not err in its judgment.View "Seacoast RV, Inc. v. Sawdran, LLC" on Justia Law

The Leonards entered into contracts with Centennial for the sale of a log home kit and construction of a custom log home. The Leonards later released Centennial from any claims for damages for defective construction or warranty arising out of the home's construction. Greg and Elvira Johnston held a thirty-six percent interest in the property at the time the release was signed. Eventually, all interest in the property was transferred to the Elvira Johnston Trust. A few years later, because of a number of construction defects affecting the structural integrity of the house, the Johnstons decided to demolish the house. The Johnstons sued Centennnial for negligent construction, breach of statutory and implied warranties, and other causes of action. The district court granted summary judgment for Centennial, finding that the Johnstons' claims were time-barred and were waived by the Leonards' release. The Supreme Court (1) reversed the court's ruling that the Johnstons' claims were time-barred and directed that the decision on remand apply only to the interest owned by the Johnstons at the time the release was executed; and (2) affirmed the district court's conclusion that the release was binding on the Leonards' sixty-four percent interest, later transferred to the Trust. View "Johnston v. Centennial Log Homes & Furnishings, Inc." on Justia Law