Volvo Trucks North America, Inc. v. Reeder-Simco GMC, Inc.

Volvo Trucks North America, Inc. (Volvo) (defendant) manufactured heavy-duty trucks. Volvo sold its trucks at a wholesale discount to dealers through a bidding process, and the dealers sold the trucks to retail customers. Dealers generally sold in exclusive geographic territories. Volvo determined that it sold to too many dealers and sought to reduce the number of dealers from 146 to 75. Reeder-Simco GMC, Inc. (Reeder) (plaintiff) was a heavy-duty-truck dealer that sold Volvo trucks. Reeder learned that Volvo gave a wholesale discount to another dealer that was greater than the discount Volvo usually gave Reeder. Reeder brought suit, alleging a violation of the Robinson-Patman Act. At trial, Reeder compared discounts it received on successful bids against non-Volvo dealers, with the higher discounts other Volvo dealers received on different sales on which Reeder did not bid (purchase-to-purchase comparisons). Reeder also compared discounts it was offered on its unsuccessful bids against non-Volvo dealers, with the higher discounts other Volvo dealers received when they won different sales on which Reeder did not bid (offer-to-purchase comparisons) Finally, Reeder presented evidence of two instances in which it lost a head-to-head bid against another Volvo dealer (head-to-head comparisons). In one head-to-head bidding competition, both Volvo dealers lost the bid; in the other, Volvo’s discount offers to the winning bidder and Reeder were initially the same, but Volvo ultimately increased its discount offer to the winning bidder after it won the bid. The United States Court of Appeals for the Eighth Circuit affirmed the trial court’s judgment in favor of Reeder. Volvo appealed, and the United States Supreme Court granted certiorari.