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Craftsmen Limousine, Inc. v. Ford Motor Co.

Citations: 363 F.3d 761; 64 Fed. R. Serv. 454Docket: No. 03-1441, 03-1544, 03-1444, 03-1546

Court: Court of Appeals for the Eighth Circuit; April 13, 2004; Federal Appellate Court

Narrative Opinion Summary

This case involves Craftsmen Limousine, Inc. and JMRL Sales Service, Inc., collectively known as 'Craftsmen,' who filed an antitrust lawsuit against American Custom Coach, American Coach, other limousine manufacturers, and Ford Motor Company. Craftsmen alleged that these defendants conspired to restrict their advertising in industry trade publications and participation in trade shows, violating Section 1 of the Sherman Act. The jury found in favor of Craftsmen, awarding them $2,109,707, which was later trebled by the district court to $5,941,621. The defendants' appeals led to a partial affirmation and reversal by the court. The case examined the applicability of per se versus rule of reason analysis, deciding that the latter was more appropriate for evaluating the alleged anticompetitive practices related to Ford's Quality Vehicle Modifier (QVM) program. The court also evaluated expert testimony under the Daubert standard, ultimately requiring a new trial for the Sherman Act claims. Despite the allegations, evidence indicated Craftsmen's compliance with federal safety standards, though disagreements persisted over the motivations behind Ford's safety protocols and their impact on market competition. The court vacated the damages award and remanded the case, with Craftsmen settling with all defendants except Ford and American Coach.

Legal Issues Addressed

Admissibility and Reliability of Expert Testimony

Application: The district court found the expert testimony of David Cole relevant and reliable under the Daubert standard for the jury's consideration.

Reasoning: The district court deemed Cole’s testimony relevant and reliable for the jury's consideration.

Antitrust Violations under the Sherman Act

Application: The case involves allegations of a conspiracy to exclude Craftsmen from advertising and trade shows, violating Section 1 of the Sherman Act.

Reasoning: Defendants claim there is insufficient evidence for a reasonable jury to conclude they conspired to exclude Craftsmen from advertising or attending trade shows.

Application of Per Se vs. Rule of Reason Analysis in Antitrust Cases

Application: The court determined that the rule of reason analysis was appropriate rather than the per se rule for evaluating Ford's QVM program and its implications.

Reasoning: The Seventh Circuit determined that the plaintiff's claim required a rule of reason analysis instead of a per se analysis.

Federal Motor Vehicle Safety Standards Compliance

Application: Craftsmen argued compliance with safety standards while Ford's QVM program aimed to enforce these standards among coachbuilders.

Reasoning: Craftsmen claimed they were unfairly excluded from the market due to pressure from defendants on trade publications.

Treble Damages and Attorney Fees Under Antitrust Law

Application: Craftsmen sought to treble the damages and requested attorney fees after the jury awarded them $2,109,707.

Reasoning: Craftsmen subsequently moved to treble the damages and sought attorney fees. The district court denied the defendants' post-trial motions, granted Craftsmen's request for fees, and increased the damage award to $5,941,621.