Matsushita Electric Industrial Co. v. Zenith Radio Corp. case brief
Matsushita Electric Industrial Co. v. Zenith Radio Corp. case
475 U.S. 574 (1986)
Petitioners challenged a decision from
the United States Court of Appeals for the Third Circuit that
reversed a summary judgment decision in favor of petitioners, who
were defendants in an antitrust conspiracy case.
CASE FACTS Respondents, domestic electronics
companies, brought an antitrust conspiracy suit against petitioners,
Japanese electronics companies. Respondents claimed that petitioners
conspired to depress prices in the American market in order to drive
out American competitors. The district court granted summary judgment
for petitioners, but the appellate court reversed based on its
finding of direct evidence of concert of action.
The Court granted
certiorari to determine whether the court of appeals applied the
proper standard in evaluating the summary judgment decision.
Court concluded that the court of appeals erred in two respects:
First, the direct evidence on which the court of appeals relied had
little, if any, relevance to the alleged predatory pricing
Second, the court of appeals failed to consider the
absence of a plausible motive to engage in predatory pricing.
decision was reversed and remanded for the court of appeals to
consider any evidence that petitioners conspired to price predatorily
despite the lack of any apparent motive to do so.
In the absence of
such evidence, the Court instructed that petitioners were entitled to
have summary judgment reinstated.
CONCLUSION The decision reversing the summary
judgment for petitioners was reversed and remanded based on the
Court's holding that the court of appeals erred by relying on
irrelevant evidence and failing to consider the absence of a
plausible motive for petitioners to engage in predatory pricing.
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