Williamson v. Columbia Gas & Electric Corp.

186 F.2d 464, 341 U.S. 921, 71 S.Ct. 743 (1951)

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Williamson v. Columbia Gas & Electric Corp.

United States Court of Appeals for the Third Circuit
186 F.2d 464, 341 U.S. 921, 71 S.Ct. 743 (1951)

Facts

Williamson (plaintiff) organized a company and entered into the gas business. Columbia Gas & Electric Corp. (defendant), in an effort to destroy its competitor, acquired the controlling interest in Williamson’s company and manipulated its affairs in such a way that Williamson was forced into bankruptcy. Williamson brought suit in the United States District Court for the District of Delaware against Columbia and certain others, alleging that his injuries were caused by their conspiracy against him in violation of the anti-trust laws. Subsequently, Williamson sued Columbia alone in the same court for recovery of the same injuries caused by the defendant’s alleged violation of the anti-trust laws. This second action came to a conclusion first. The district court dismissed the complaint. Thereafter, Columbia moved for summary judgment in the first action because of its victory in the second action. Columbia’s motion was granted by the district court. Williamson appealed, arguing that the two actions were not substantially identical, and thus the judgment on the merits in favor of Columbia in the second action did not preclude his maintenance of the first action.

Rule of Law

Issue

Holding and Reasoning (Goodrich, J.)

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