Town of Hallie v. City of Eau Claire

471 U.S. 34 (1985)

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Town of Hallie v. City of Eau Claire

United States Supreme Court
471 U.S. 34 (1985)

Facts

Several unincorporated townships (the towns) (plaintiffs) in Wisconsin brought a suit against the City of Eau Claire (the city) (defendant), seeking injunctive relief from alleged antitrust violations. Specifically, the towns contended that the city had used its monopoly position in sewage treatment to establish monopolies in sewage-collection-and-transportation services through an unlawful tying arrangement. The city operated the only sewage-treatment facility available to the towns and refused to supply sewage services unless a majority of landowners in the areas around the towns agreed both to be annexed by the city and to utilize the city’s sewage-collection-and-transportation services. The city argued that its anticompetitive actions were immune from antitrust law under the state-action doctrine, because the city acted within the scope of a Wisconsin statute that authorized cities to construct sewage systems and define the areas of service. The court of appeals found in favor of the city. The towns appealed on the issue of whether the city qualified for antitrust immunity under the state-action doctrine.

Rule of Law

Issue

Holding and Reasoning (Powell, J.)

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