Williamson v. Columbia Gas & Electric Corp. case brief

Williamson v. Columbia Gas & Electric Corp. case brief summary
186 F.2d 464 (1950)

CASE SYNOPSIS

Plaintiff appealed a judgment of the United States District Court for the District of Delaware that granted defendant's motion to dismiss plaintiff's conspiracy to violate anti-trust law claim based on res judicata.

CASE FACTS
Plaintiff filed a complaint against defendant that alleged defendant and others conspired to violate anti-trust laws ("conspiracy claim"). Plaintiff subsequently filed a complaint against defendant that alleged defendant violated the anti-trust laws ("anti-trust claim"). The trial court dismissed the anti-trust claim. Based on that judgment, defendant filed a motion to dismiss the conspiracy claim.

DISCUSSION

• The court held that res judicata prevented plaintiff from maintaining the conspiracy claim because the information set forth in both complaints and the damage claims were substantially identical. 
• The fact that conspiracy was alleged in the conspiracy claim but not the anti-trust claim did not change the substance of the claims, and plaintiff's reliance on different statutes for each claim did not render the claims separate causes of action for purposes of res judicata.

CONCLUSION
The judgment dismissing plaintiff's conspiracy to violate anti-trust law claim was affirmed because res judicata prevented plaintiff from maintaining the conspiracy claim where the information in the complaint and damage claim were substantially identical to that of plaintiff's claim that alleged defendant violated anti-trust law.

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