Moore v. New York Cotton Exchange
United States Supreme Court
270 U.S. 593, 46 S.Ct. 367, 70 L.ed. 750 (1926)
The New York Cotton Exchange (the New York exchange) (defendant) is in the business of making contracts for the future sale of cotton. The New York exchange collects quotations of cotton prices and uses telegraph services to distribute the quotations to recipients approved by the New York exchange. The Odd-Lot Cotton Exchange (the Odd-Lot exchange) applied to receive quotations from the New York exchange. The New York exchange denied the application on the grounds that the Odd-Lot exchange was essentially a successor to a previous exchange that had been convicted of fraudulent activity and that it had been organized for the purpose of conducting fraudulent activity. The Odd-Lot exchange's president, Moore (plaintiff), brought a federal antitrust complaint, alleging that the New York exchange had a monopoly over cotton quotations. The complaint sought to enjoin the New York exchange from refusing to furnish quotations to the Odd-Lot exchange. The New York exchange’s answer asserted a counterclaim, alleging that although Odd-Lot was not permitted to receive quotations, it had nevertheless obtained them through unauthorized means and was using them to engage in fraudulent activity. The New York exchange’s counterclaim sought an injunction to stop this practice. Both parties requested interlocutory injunctions. The district court granted the New York exchange’s request and denied the Odd-Lot exchange’s request. The United States Court of Appeals for the Second Circuit affirmed the orders. The district court ultimately dismissed the Odd-Lot exchange’s antitrust cause of action. The Odd-Lot exchange appealed the district court’s grant of the injunction sought in the New York exchange’s counterclaim. The Odd-Lot exchange argued that dismissal of the counterclaim was required, because (1) the counterclaim did not arise out of the same transaction that was the subject matter of the suit, and (2) there was no independent basis for jurisdiction.
Rule of Law
Holding and Reasoning (Sutherland, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 726,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 726,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 45,700 briefs, keyed to 983 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.