Mandeville Island Farms v. American Crystal Sugar

334 U.S. 219 (1948)

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Mandeville Island Farms v. American Crystal Sugar

United States Supreme Court
334 U.S. 219 (1948)

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Facts

Mandeville Island Farms (Mandeville) (plaintiff) was a sugar-beet farmer based in California. Mandeville sold its beets to American Crystal Sugar Co. (defendant). American Crystal Sugar was one of three sugar refiners in California, all of which processed the beets they purchased into sugar for sale on an interstate market. The three Californian refiners comprised the entire sales market for Californian beet farmers; a farmer’s alternative to selling to one of those three refiners was to stop selling beets, giving the refiners a dominant market position. Initially, each refiner purchased beets from farmers like Mandeville at a price set by combining the beets’ sugar content and the refiner’s profits per 100 pounds of sugar. That changed when all three refiners agreed to charge farmers based on their collective average profits, resulting in each refiner charging the same price to each beet farmer. The refiners would then sell the end sugar product across state lines. As the most efficient refiner, American Crystal Sugar’s purchase prices to farmers decreased. Mandeville sued for violations of Sherman Act §§ 1 and 2. The lower courts dismissed the complaint.

Rule of Law

Issue

Holding and Reasoning (Rutledge, J.)

Dissent (Jackson, J.)

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