Albert Pick-Barth Co. v. Mitchell Woodbury Corp.

57 F.2d 96 (1932)

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Albert Pick-Barth Co. v. Mitchell Woodbury Corp.

United States Court of Appeals for the First Circuit
57 F.2d 96 (1932)

Facts

Boston-based Mitchell Woodbury Corp. (plaintiff) was a major company in the New England market for kitchen equipment and utensils. Albert Pick-Barth Co. (Pick-Barth) (defendant) sought to make gains in the same field and geographical area. Mitchell Woodbury brought an action against Pick-Barth in federal district court, alleging unfair competition in violation of the Sherman Antitrust Act and the Clayton Act. The jury found that two trusted Mitchell Woodbury employees, Stuart and McDonald (defendants), had left Mitchell Woodbury to work for Pick-Barth as part of a conspiracy between the employees and Pick-Barth to take over Mitchell Woodbury’s business. This included Stuart and McDonald’s delivery of Mitchell Woodbury’s customer lists, records, and plans to Pick-Barth. However, the jury also found that the conspiracy had been largely unsuccessful and that it had not resulted in any unreasonable restraint on interstate trade. The judge directed a verdict for Mitchell Woodbury. Pick-Barth appealed to the United States Court of Appeals for the First Circuit, arguing that there could be no finding of federal antitrust liability without a finding of unreasonable restraint on interstate trade.

Rule of Law

Issue

Holding and Reasoning (Wilson, J.)

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