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Spectrum Sports, Inc. v. McQuillan

Citations: 122 L. Ed. 2d 247; 113 S. Ct. 884; 506 U.S. 447; 1993 U.S. LEXIS 1013; 93 Daily Journal DAR 1069; 61 U.S.L.W. 4123; 93 Cal. Daily Op. Serv. 529; 6 Fla. L. Weekly Fed. S 899Docket: 91-10

Court: Supreme Court of the United States; January 25, 1993; Federal Supreme Court; Federal Appellate Court

Narrative Opinion Summary

The case involves a dispute over alleged violations of Section 2 of the Sherman Act by a national distributor of sorbothane athletic products. The respondents, former distributors, claimed that the petitioners engaged in monopolistic practices after they were excluded from the market. The District Court found the petitioners liable and the Court of Appeals affirmed the ruling. However, the Supreme Court reversed this decision, emphasizing that for attempted monopolization under the Sherman Act, proof of both a dangerous probability of monopolization and specific intent is required. The Court criticized the lower courts for allowing the jury to infer intent and probability of monopolization without evidence of the relevant market. This decision aligns with the Sherman Act's purpose to protect competition rather than penalize competitive conduct. The case was remanded for further proceedings, highlighting the need for courts to avoid interpretations that could stifle competition by requiring a thorough examination of market power and relevant market in antitrust cases.

Legal Issues Addressed

Elements of Attempted Monopolization under Sherman Act Section 2

Application: The Supreme Court held that liability for attempted monopolization requires proof of both a dangerous probability of monopolization and specific intent to monopolize.

Reasoning: The Supreme Court held that liability for attempted monopolization requires proof of both a dangerous probability of monopolization and specific intent to monopolize.

Evidence Required for Attempted Monopolization

Application: The Court criticized the jury's ability to infer intent and a dangerous probability of monopolization solely from predatory conduct without evidence of the relevant market.

Reasoning: The Court emphasized that proving intent alone is inadequate for establishing the probability of success, which necessitates an examination of the relevant market and the defendant’s market power.

Judicial Interpretation of Section 2 of the Sherman Act

Application: The Supreme Court reversed the Ninth Circuit's ruling, stating that the affirmance of the judgment was based on an erroneous legal interpretation that allowed for liability without adequate evidence of market power.

Reasoning: The Court found that both the jury instructions and the Court of Appeals' judgment misinterpreted Section 2 of the Sherman Act, specifically regarding allegations of attempted monopolization against the petitioners.

Protection of Competition under Sherman Act

Application: The Court asserted that the Sherman Act aims to protect competition rather than penalize competitive behavior.

Reasoning: The Court criticized the approach taken in previous cases like Lessig v. Tidewater Oil Co., asserting that the Sherman Act aims to protect competition rather than penalize competitive behavior.

Relevance of Market Definition in Monopolization

Application: The Court underscored that merely demonstrating 'unfair' or 'predatory' conduct does not suffice to prove dangerous probability of monopolization without a thorough examination of the relevant market.

Reasoning: Merely demonstrating 'unfair' or 'predatory' conduct does not suffice to prove dangerous probability of monopolization; a thorough examination of the relevant market and the defendant's economic power is necessary.