Stephen Jay Photography, Ltd. v. Olan Mills, Inc.

903 F.2d 988 (1989)

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Stephen Jay Photography, Ltd. v. Olan Mills, Inc.

United States Court of Appeals for the Fourth Circuit
903 F.2d 988 (1989)

Facts

Olan Mills, Inc., and Kinder-Care (defendants) contracted with local schools to provide photography services to students, including yearbook pictures. The contracts did not require any students to have their pictures taken, but it did declare that Olan Mills and Kinder-Care would pay the schools a portion of any profit they made from taking student pictures. The schools, in turn, sent letters to parents strongly encouraging them to purchase school pictures from either Olan Mills or Kinder-Care. This gave both companies a competitive advantage over other photography companies. Several other photography companies, including Stephen Jay Photography, Ltd. (collectively, Stephen Jay) (plaintiffs), brought suit against Olan Mills and Kinder-Care under § 2(c) of the Robinson-Patman Act in federal district court. Stephen Jay alleged that the agreement of Olan Mills and Kinder-Care to give the schools a portion of the profits from the student photographs amounted to commercial bribery. It was undisputed that no agency relationship existed between the schools and the students—that is, the schools did not have any authority to require the students to get their pictures taken by either Olan Mills or Kinder-Care. Nevertheless, Stephen Jay argued that the schools acted as intermediaries on behalf of the students in signing the contracts with Olan Mills and Kinder-Care. The district court granted summary judgment in favor of Olan Mills and Kinder-Care. Stephen Jay appealed.

Rule of Law

Issue

Holding and Reasoning (Wilkins, J.)

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