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Camarda v. Snapple Distributors, Inc.
Citation: 346 F. App'x 690Docket: No. 07-4538-cv
Court: Court of Appeals for the Second Circuit; September 22, 2009; Federal Appellate Court
Plaintiffs-appellants, Mitchell Camarda et al., appeal a summary judgment from September 18, 2007, favoring defendants-appellees Snapple Distributors, Inc., Snapple Finance Corp., Snapple Beverage Corporation, and Snapple Beverage Group, Inc. The United States District Court for the Southern District of New York dismissed the plaintiffs’ secondary-line price discrimination claim under the Robinson-Patman Act due to their failure to demonstrate actual injury. A claim under this Act requires proof of both a violation and actual injury, which must be established as an injury-in-fact caused by the violation and not attributable to unrelated factors. The plaintiffs did not show evidence of how other factors may have contributed to their loss of customers, which is necessary to link the alleged price discrimination to the claimed injuries. The court highlighted that mere awareness of a transshipping issue by the defendants does not establish causation for the plaintiffs’ injuries. Other unrelated factors, such as consumer preferences and competitive pricing strategies, could also explain the plaintiffs’ business decline. Thus, the plaintiffs' argument that they were not required to account for these factors was rejected. The dismissal of their state-law breach of contract claims followed as the court declined to exercise supplemental jurisdiction after dismissing the primary claim. The District Court's conclusion that the plaintiffs did not demonstrate 'actual injury' from the defendants’ alleged violation of the Robinson-Patman Act is upheld. The plaintiffs' request for a remand to present additional causation evidence is denied, as they had ample opportunity during the lower court proceedings to introduce such evidence but failed to do so. They did not ask the District Court to consider other causal factors either. The Court also refuses to remand for a defense raised for the first time on appeal. Consequently, the dismissal of the plaintiffs’ federal claim under the Robinson-Patman Act is deemed appropriate, and there is no abuse of discretion in the District Court's choice not to exercise supplemental jurisdiction over the remaining state-law claims. The judgment of the District Court is thus affirmed. Additionally, the excerpt notes that 'transshipping' can occur when there is a significant price difference between neighboring markets, allowing products to be bought in a lower-priced area and sold in a higher-priced one.