Friday, December 6, 2013

Hartford Fire Insurance Co. v. California case brief

Hartford Fire Insurance Co. v. California case brief summary
509 U.S. 764 (1993)


CASE SYNOPSIS
On consolidated appeals, defendant insurers challenged an order from the United States Court of Appeals for the Ninth Circuit, which reversed the dismissal of plaintiffs' action and held that defendants could not claim McCarran-Ferguson Act, 15 U.S.C.S. § 1012(b), antitrust immunity. Plaintiffs alleged that defendants violated the Sherman Act, 15 U.S.C.S. § 1, by engaging in various conspiracies to affect the American insurance market.

CASE FACTS
Defendant foreign and domestic insurers were not entitled to a dismissal under the McCarran-Ferguson Act (the Act), 15 U.S.C.S. § 1012(b), when plaintiffs alleged antitrust violations under the Sherman Act, 15 U.S.C.S. § 1 because the complaint properly alleged the boycott exception to antitrust immunity under the Act. Plaintiffs alleged that defendants violated antitrust laws for various conspiracies to affect the American insurance market. Defendants contended that the Act granted defendants antitrust immunity for the business of insurance that was regulated by state law.

DISCUSSION

  • The court affirmed the appellate court's refusal to dismiss the complaint because the claims fell within the boycott exception to antitrust immunity. 
  • The court, however, reversed the holding that defendant domestic insurers were not entitled to antitrust immunity simply because they acted with defendant foreign insurers.

CONCLUSION
The court affirmed the appellate court's holding that it was error for the district court to dismiss plaintiffs' complaint of antitrust violations under the Act because the boycott exception to antitrust immunity was applicable. The court reversed the holding of the appellate court that defendant domestic insurers were bereft of the Act's exemption simply because they acted with foreign defendant insurers. The cases were remanded.


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