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Cia. Petrolera Caribe, Inc. v. Avis Rental Car Corporation
Citations: 735 F.2d 636; 1984 U.S. App. LEXIS 21856Docket: 84-1034
Court: Court of Appeals for the First Circuit; June 4, 1984; Federal Appellate Court
Cia. Petrolera Caribe, Inc. initiated a lawsuit against Avis, Hertz, and National Rental Car Corporations, alleging violations of the Clayton and Sherman Acts due to an illegal tying arrangement. Caribe claimed that the rental car companies tied the sale of gasoline, which they had no significant market power over, to the rental of cars, over which they did have market power. The district court granted summary judgment for the defendants, stating that Caribe lacked standing as a wholesaler and had not provided evidence of coercion in the sale of gasoline. The rental car companies offered a full tank of gas with each rental, imposing a refueling charge if the tank was not full upon return, but did not require lessees to buy gas from them. Caribe argued that this policy effectively forced customers to purchase gas from the rental companies. However, the court noted the absence of any customer affidavits or evidence of coercion, with Caribe's vice-president confirming that customers had the option to fill up elsewhere before returning the vehicles. The appellate court affirmed the district court's decision. The district court determined that Mr. Lopez was not informed that he had to purchase gas exclusively from Avis when renting a car, nor was he prohibited from refueling at another source. Caribe claimed that if allowed to conduct discovery, it could show a significant percentage of rental customers return cars with partially empty tanks, suggesting a practice where rental companies refill the tanks for them. However, evidence of a high percentage of customers buying gas from rental companies alone would not establish coercion. Caribe argued that rental companies charge 30-40% more per gallon than retail stations in Puerto Rico and fail to adequately inform customers of this markup. Caribe's claim hinges on the assertion that rental companies 'coerce' customers into purchasing gas due to insufficient prior warning about the higher charges. Nonetheless, the record does not indicate that any customer inquiries about refueling charges went unanswered. Customers are presumed to know they can refuel their cars to avoid extra charges. While some customers might opt for convenience in allowing the rental companies to refill their tanks, ignorance of the higher price does not equate to coercion under antitrust laws. Caribe's inability to demonstrate a genuine issue of material fact led to the proper granting of summary judgment by the district court, and the issue of standing was deemed unnecessary to address. The ruling was affirmed.