Wee Care Child Center, Inc. v. Lumpkin

Wee Care Child Center, Inc. (plaintiff) was an Ohio daycare center that provided childcare services for children of low-income families. Wee Care was licensed to operate by the Ohio Department of Job and Family Services (state) (defendant) and relied on funding contracts under Title XX of the Social Security Act, which were distributed by the Franklin County Department of Job and Family Services (county) (defendant). When allegations came to light that Wee Care failed to provide a safe environment for children, the state declined to renew Wee Care’s operating license and the county discontinued funding. Wee Care thereafter initiated a number of suits against the state and county defendants in both state and federal court, each of which was dismissed with the exception of this present suit. In this present suit, Wee Care alleged that the state and county violated Section 1 of the Sherman Antitrust Act and that the county tortiously interfered with its contracts and business relationships. The district court granted the state’s motion to dismiss under Federal Rule of Civil Procedure (FRCP) 12(b)(6) for failure to state a claim. The district court also granted the county’s motion for judgment on the pleadings under FRCP (12)(c), finding the county immune from suit under the Local Government Antitrust Act of 1984 (LGAA) and otherwise declined to exercise supplemental jurisdiction over the remaining state-law claims. Wee Care appealed.