California v. ARC America Corp.

490 U.S. 93, 109 S. Ct. 1661, 104 L. Ed. 2d 86 (1989)

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California v. ARC America Corp.

United States Supreme Court
490 U.S. 93, 109 S. Ct. 1661, 104 L. Ed. 2d 86 (1989)

Facts

Numerous federal lawsuits were filed against a group of companies (defendants) accused of engaging in a nationwide conspiracy to fix cement prices. The claimants included direct purchasers of cement and indirect purchasers of cement. California and other states (states) (plaintiffs) filed suit, primarily as indirect purchasers. The states asserted federal antitrust claims as well as claims pursuant to their own respective antitrust laws. Each state’s antitrust law provided a cause of action for indirect purchasers. The lawsuits were transferred to a single district court for pretrial proceedings and were certified as class actions. Several of the companies settled, resulting in the establishment of a $32 million settlement fund intended to cover both the federal and the state-law claims asserted in the lawsuits. The states sought payment from the fund for their state-law indirect-purchaser claims. The federal claimants objected, noting that a federal rule established in Illinois Brick Co. v. Illinois, 431 U.S. 720 (1977), barred indirect purchasers from asserting federal antitrust claims. The federal claimants argued that Illinois Brick also preempted the state antitrust laws, thus barring all claims by indirect purchasers of cement. The district court disallowed the states’ indirect-purchaser claims, and the court of appeals affirmed. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (White, J.)

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