American Society of Mechanical Engineers, Inc. v. Hydrolevel Corporation
United States Supreme Court
456 U.S. 556 (1982)
American Society of Mechanical Engineers, Inc. (ASME) (defendant) was a nonprofit organization that set engineering standards for the industry. The standards were voluntary but were widely accepted and used. Hydrolevel Corporation (plaintiff) developed a new safety device for water boilers. John W. James was vice president of a competitor of Hydrolevel. James was also the vice chairman of an ASME subcommittee that set standards for products like Hydrolevel’s. James requested a determination from ASME on the Hydrolevel device’s compliance with the applicable ASME code. T. R. Hardin, the chair of the ASME subcommittee, gave an unofficial response on ASME letterhead that the Hydrolevel product was unsafe. The response became public, and the success of Hydrolevel’s product was harmed. Hydrolevel sued ASME under the Clayton Act. The jury returned a verdict for Hydrolevel. The court of appeals affirmed, finding that ASME could be held liable for antitrust violations under an apparent-authority theory. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Blackmun, J.)
Dissent (Powell, J.)
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