Justia U.S. 11th Circuit Court of Appeals Opinion Summaries

Automotive body shops filed suit against major automobile insurance companies, alleging claims for relief under the Sherman Act and state law based on the insurance companies' alleged anticompetive practices.The Eleventh Circuit held that it lacked jurisdiction to decide the merits of the Indiana and Utah appeals because the orders dismissing the first amended complaints became final judgments under Hertz Corporation v. Alamo Rent-ACar, Incorporated, 16 F.3d 1126 (11th Cir. 1994), when the deadline to amend expired. However, the court held that it had jurisdiction to review the order dismissing the Mississippi body shops’ antitrust claims. The court also held that the district court correctly dismissed the antitrust claims; the district court did not abuse its discretion in denying the Mississippi body shops' motion to reconsider its dismissal of their antitrust claims; and the district court correctly dismissed most of the Mississippi body shops' claims under state law. Accordingly, the court vacated in part, affirmed in part, and remanded for further proceedings. View "Automotive Alignment & Body Service, Inc. v. State Farm Mutual Automobile Insurance Co." on Justia Law

The Body Shops filed suit alleging that defendant insurance companies colluded to lower repair prices by improperly pressuring the shops to lower prices and by threatening to boycott those who did not comply. The Body Shops claimed a per se price-fixing conspiracy and a per se conspiracy to boycott, as well as state law claims.The Eleventh Circuit affirmed the district court's dismissal of all of the Body Shop's federal antitrust and state law claims except the tortious interference claims. Although the court held that the unjust enrichment and quantum meruit claims of the Body Shops were wholly without merit, the court vacated the district court's judgment as to the tortious interference claims because the court was not persuaded by the district court's grounds for concluding that the allegations of tortious interference in each of these five cases violated the group pleading doctrine, i.e., failed to give fair notice to each defendant of the claim being made against it. The court remanded for further proceedings. View "Quality Auto Painting Center of Roselle, Inc. v. State Farm Indemnity Co." on Justia Law

The Eleventh Circuit reversed the dismissal of five complaints filed by automobile body shops, asserting federal antitrust and state tort claims against insurance companies. The court held that the shops pleaded enough facts to plausibly support their federal antitrust and state tort claims. In this case, the body shops argued that the insurance companies engaged in two lines of tactics in pursuit of a single goal: to depress the shops' rates for automobile repair. The body shops have supplied enough allegations to raise a reasonable expectation that discovery will reveal evidence of an illegal agreement; the body shops have consistently alleged the existence of parallel conduct and of plus factors allowing a plausible inference of an illegal agreement; and the allegations have sufficiently established the body shops' state tort claims of unjust enrichment, quantum meruit, and tortious interference. Accordingly, the court remanded for further proceedings. View "Quality Auto Painting Center of Roselle, Inc. v. State Farm Indemnity Co." on Justia Law

American Dawn terminated plaintiff, a restaurant linen salesman, for participating in a fraudulent scheme against ALSCO, and plaintiff later found employment with American Dawn's competitor, Baltic. After plaintiff joined Baltic, a sales manager at American Dawn and a consultant for ALSCO allegedly conspired to freeze Baltic out of the restaurant linens market. Plaintiff lost his job as a result of the alleged conspiracy and subsequently filed suit, alleging violation of the antitrust laws, 15 U.S.C. 1 et seq. The court concluded that plaintiff lacked standing to challenge a conspiracy directed at his employer even if the conspiracy caused plaintiff's termination. The court further concluded that plaintiff failed to plead claims of racketeering, tortious interference, civil conspiracy, negligent misrepresentation, and fraud. Accordingly, the court affirmed the judgment. View "Feldman v. American Dawn, Inc." on Justia Law

Procaps and Patheon are involved in the market for softgel services. Procaps filed suit under the Sherman Act, 15 U.S.C. 1, against its former joint venture partner, Patheon, alleging that Patheon's acquisition of Banner violated Section 1 of the Act. Procaps specifically alleged that the Banner acquisition placed Patheon in direct competition with Procaps, thus transforming the parties’ legitimate joint venture into a per se illegal horizontal restraint in violation of Section 1. The district court granted summary judgment to Patheon. After thorough review and having the benefit of oral argument, the court concluded that Patheon was entitled to summary judgment both because Procaps has failed to establish the foundational requirement of concerted action necessary to maintain a Section 1 claim under the Sherman Act, and because Procaps also failed to show any actual anticompetitive effects. Accordingly, the court affirmed the judgment. View "Procaps S.A. v. Patheon, Inc." on Justia Law

DFA filed suit against Estee Lauder after Estee Lauder refused to do business with DFA and communicated that fact to airport authorities evaluating whether to offer rental space to DFA. DFW alleged three claims in its amended complaint: (1) attempted monopolization, in violation of section 2 of the Sherman Act, 15 U.S.C. 2; (2) contributory false advertising, in violation of section 43(a) of the Lanham Act, 15 U.S.C. 1125(a); and (3) tortious interference with a prospective business relationship, in violation of Florida law. The district court dismissed the suit based on failure to state a claim. The court concluded that DFW failed to allege basic facts sufficient to state a claim to relief that is plausible on its face where DFW did not adequately allege that Estee Lauder engaged in predatory or anticompetitive conduct for its antitrust claims; DFA does not come close to establishing standing to seek injunctive relief from the requirements that Estée Lauder places on its competitors, inasmuch as DFA no longer does any business with Estée Lauder; DFA failed to plead sufficient facts from which a court could find that Estée Lauder made false statements, or, for that matter, was responsible for any such statements made by DFA’s competitors in DFA's false advertising claim; and the complaint failed to allege any improper conduct sufficient to constitute tortious interference with a business relationship in violation of Florida law. Accordingly, the court affirmed the judgment. View "Duty Free Americas, Inc. v. The Estee Lauder Co." on Justia Law

DFA filed suit against Estee Lauder after Estee Lauder refused to do business with DFA and communicated that fact to airport authorities evaluating whether to offer rental space to DFA. DFW alleged three claims in its amended complaint: (1) attempted monopolization, in violation of section 2 of the Sherman Act, 15 U.S.C. 2; (2) contributory false advertising, in violation of section 43(a) of the Lanham Act, 15 U.S.C. 1125(a); and (3) tortious interference with a prospective business relationship, in violation of Florida law. The district court dismissed the suit based on failure to state a claim. The court concluded that DFW failed to allege basic facts sufficient to state a claim to relief that is plausible on its face where DFW did not adequately allege that Estee Lauder engaged in predatory or anticompetitive conduct for its antitrust claims; DFA does not come close to establishing standing to seek injunctive relief from the requirements that Estée Lauder places on its competitors, inasmuch as DFA no longer does any business with Estée Lauder; DFA failed to plead sufficient facts from which a court could find that Estée Lauder made false statements, or, for that matter, was responsible for any such statements made by DFA’s competitors in DFA's false advertising claim; and the complaint failed to allege any improper conduct sufficient to constitute tortious interference with a business relationship in violation of Florida law. Accordingly, the court affirmed the judgment. View "Duty Free Americas, Inc. v. The Estee Lauder Co." on Justia Law

The issue in this case arose from alleged anticompetitive conduct in the ductile iron pipe fittings ("DIPF") market by McWane, Inc., a family-run company headquartered in Birmingham, Alabama. In 2009, following the passage of federal legislation that provided a large infusion of money for waterworks projects that required domestic pipe fittings, Star Pipe Products entered the domestic fittings market. In response, McWane, the dominant producer of domestic pipe fittings, announced to its distributors that (with limited exceptions) unless they bought all of their domestic fittings from McWane, they would lose their rebates and be cut off from purchases for 12 weeks. The Federal Trade Commission ("FTC") investigated and brought an enforcement action under Section 5 of the Federal Trade Commission Act, 15 U.S.C. sec. 45. The Administrative Law Judge ("ALJ"), and a divided Commission, found that McWane's actions constituted an illegal exclusive dealing policy used to maintain McWane's monopoly power in the domestic fittings market. The Commission issued an order directing McWane to stop requiring exclusivity from distributors. McWane appealed, challenging nearly every aspect of the Commission's ruling. After thorough review, the Eleventh Circuit found the Commission's factual and economic conclusions were supported by substantial evidence in the record. Accordingly, the Court affirmed the Commission's ruling. View "McWane, Inc. v. Federal Trade Commission" on Justia Law

Astellas holds patents on a cardiac test and sells its unpatented pharmaceutical product, Adenoscan, for using during that test. The Medical Center, which conducts cardiac tests, filed suit under Section 1 of the Sherman Act, 15 U.S.C. 1, alleging that Astellas is able to overcharge the Medical Center for the Adenoscan product by unlawfully tying the patented right to perform the patented cardiac test to the purchase of the unpatented Adenoscan. The court concluded that the district court did not abuse its discretion in refusing the Medical Center's request to certify a class seeking damages against Astellas for unlawful tying because the direct purchaser rule precludes the Medical Center's own treble damages claim. The district court also did not abuse its discretion in refusing to certify the class for purposes of seeking injunctive and declaratory relief. Accordingly, the court affirmed the judgment of the district court.View "Lakeland Regional Medical Center v. Astellas US, LLC, et al." on Justia Law

In 2000, physicians and physician associations imitated a group of class actions against various providers of health plans, which were consolidated into a multidistrict litigation. This appeal involves this complex, twelve-year-old multidistrict litigation, a related multidistrict litigation pending in another federal district, and whether the district court reasonably interpreted the Settlement Agreement in the first action. The court affirmed the Injunction as to plaintiffs' Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1961, and antitrust claims and as to the Employee Retirement Income Security Act of 1974, 29 U.S.C. 1001 et seq., claims based on the denial or underpayment of benefits following the Settlement Agreement's Effective Date. On remand, the district court will need to determine which of plaintiffs' ERISA claims fall on the permissible side of the line, and reconsider the assessment of sanctions. View "Medical Assoc. of GA, et al. v. Wellpoint, Inc." on Justia Law