Law School Case Brief
Pierce v. Ramsey Winch Co. - 753 F.2d 416 (5th Cir. 1985)
In reviewing a claim that a jury has been erroneously instructed, a reviewing court views the charge as a whole, in the context of the entire case, and it ignores technical imperfections. A reviewing court must determine not whether the charge was faultless in every particular, but whether the jury was misled in any way and whether it had understanding of the issues and its duty to determine those issues. A reviewing court will reverse if the charge as a whole leaves the court with substantial and ineradicable doubt whether the jury has been properly guided in its deliberations. A reviewing court will not reverse if it finds, based on the record, that the challenged instruction could not have affected the outcome of the case.
Plaintiff Pierce Sales ("Pierce") distributed winches made by Ramsey Winch Company ("Ramsey"). Pierce sold the winches at a low price. Ramsey's other distributors complained that Pierce's prices were too low. Ramsey forced Pierce to raise its prices and to have its advertising approved by Ramsey. Pierce complied and continued to sell Ramsey's winches. Pierce later obtained a list of Ramsey's other distributors and mailed them a list of its current winch inventory and the prices at which that inventory could be purchased. Because Pierce kept its costs down, it was able to sell winches to the other distributors at prices lower than what Ramsey could offer. Upon learning of Pierce's list, Ramsey terminated Pierce's distributorship. Pierce filed an antitrust action against Ramsey in federal district court, alleging a vertical price-fixing conspiracy between Ramsey and its other distributors. The court awarded Pierce treble damages.
Was the award of damages proper?
The judgment for plaintiff was affirmed. The federal appellate court held that there was substantial evidence to show that Pierce suffered injury from Ramsey's termination of its distributorship.
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