Holloway v. Arkansas case brief

Holloway v. Arkansas case brief summary
438 U.S. 475 (1978)

CASE SYNOPSIS

Certiorari was granted to the United States Court of Appeals for the Third Circuit, which reversed the convictions of respondents, six manufacturers and various of their corporate officials, for violations of the Sherman Act, 15 U.S.C.S. § 1, in petitioner United States' action.

DISCUSSION

• The Supreme Court affirmed a judgment reversing the convictions of respondents, six manufacturers and their corporate officials, for violations of the Sherman Act, 15 U.S.C.S. § 1, in petitioner United States' action. 
• The jury instructions regarding the elements of the price-fixing offense charged in the indictment were error because an "effects alone" test could not be applied. 
• The Court held that a defendant's state of mind or intent was an element of a criminal antitrust offense. 
• Ultimately the decision on the issue of intent must be left to the trier of fact. 
• The good-faith standard remained the benchmark against which the seller's conduct was to be evaluated. 
• The Court agreed with the court of appeals that reversal was required not only because of infirmities in the antitrust instruction, but also because the trial judge had encroached on the jury's authority and had foreclosed a possible no verdict outcome by the ex parte communications. 
• The Court concluded that the charge concerning participation in the conspiracy was sufficient, but the instruction on withdrawal was error because it limited the jury's consideration.

CONCLUSION
The judgment, which reversed the convictions of respondents, six manufacturers and various of their corporate officials, for antitrust violations in petitioner United States' action, was affirmed because the jury instructions regarding the price-fixing offense elements and on withdrawal from the conspiracy were reversible error and the trial judge had encroached on the jury's authority by the ex parte communications.

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