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Law School Case Brief

Cal. Motor Transp. Co. v. Trucking Unlimited - 404 U.S. 508, 92 S. Ct. 609 (1972)

Rule:

Any carrier has the right of access to agencies and courts, within the limits, of course, of their prescribed procedures, in order to defeat applications of its competitors for certificates as highway carriers, and the carrier's purpose to eliminate an applicant as a competitor by denying him free and meaningful access to the agencies and courts may be implicit in that opposition.

Facts:

The complaint in a civil suit, instituted under 4 of the Clayton Act in the United States District Court for the Northern District of California, alleged that the defendant Trucking Unlimited had conspired to put the plaintiff California Motor Transport Co. out of business as competitors by instituting actions in state and federal proceedings to resist and defeat the plaintiffs' applications concerning operating rights, and that the defendants had combined to deter the plaintiffs from having "free and unlimited access" to the agencies and courts, and to defeat such right by massive, concerted, and purposeful activities of the combination. The District Court dismissed the complaint for failure to state a cause of action, but the United States Court of Appeals for the Ninth Circuit reversed. Defendant Trucking Unlimited petitioned for certiorari review.

Issue:

Did petitioners have the right of access to agencies and courts in order to defeat applications of respondents for certificates as highway carriers?

Answer:

Yes

Conclusion:

The court held that petitioners had the right of access to agencies and courts in order to defeat applications of respondents for certificates as highway carriers. However, the court held that the purpose to eliminate respondents as competitors by denying them free and meaningful access to the agencies and courts might have been implicit in that opposition. In affirming the judgment and remanding the case for trial, the court stated that if such facts were proven, a violation of the antitrust laws would be established, so respondents had alleged a cause of action.

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