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United States v. Waste Management, Inc.

United States Court of Appeals for the Second Circuit
743 F.2d 976 (1984)


Waste Management, Inc. (WMI) (defendant) acquired EMW Ventures, Inc. (EMW) (defendant). The United States government (plaintiff) brought suit under the Clayton Act, alleging that the merger was anticompetitive. After the acquisition, WMI’s market share in the trash collection business in Dallas County, the relevant geographic area, was 48.8 percent. The district court treated this market share as prima facie evidence that the merger was illegal. The evidence before the district court demonstrated that entry into the relevant market was easy, both for entrepreneurs who could decide to start new trash-collection businesses and for existing trash collectors who could expand their service area into Dallas County. However, the court concluded that ease of entry was not sufficient to rebut the prima facie showing of illegality. The district court thus concluded that the acquisition violated the Clayton Act. WMI and EMW appealed.

Rule of Law


Holding and Reasoning (Winter, J.)

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