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Noerr shields from the Sherman Act, 15 U.S.C.S. § 1 et seq., a concerted effort to influence public officials regardless of intent or purpose.
The trustees of the United Mine Workers of America Welfare and Retirement Fund sued respondents, partners in a coal mining company, for royalty payments under the National Bituminous Coal Wage Agreement of 1950, as amended. Respondents filed a cross claim for damages, alleging that the trustees, the UMW and certain large coal operators had conspired to restrain and monopolize commerce in violation of §§ 1 and 2 of the Sherman Act. It was alleged that, to eradicate overproduction in the coal industry, the UMW and large operators agreed to eliminate the smaller companies, by imposing the terms of the 1950 Agreement on all companies regardless of ability to pay, by increasing royalties due the welfare fund, by excluding the marketing, production and sale of nonunion coal, by refusing to lease coal lands to nonunion operators and refusing to buy or sell coal mined by such operators, by obtaining from the Secretary of Labor the establishment of a minimum wage under the Walsh-Healey Act higher than that in other industries, by urging TVA to curtail spot market purchases which were exempt from the Walsh-Healey order, and by waging a price-cutting campaign to drive small companies out of the spot market. Petitioner's motions to dismiss were denied and the jury returned a verdict against the trustees and the UMW. The trial court set aside the verdict against the trustees but overruled the union's motion for judgment notwithstanding the verdict or for a new trial. The Court of Appeals affirmed, ruling that the union was not exempt from liability under the Sherman Act under the facts of the case.
Could the respondent collect any damages under the Sherman Act for any injury it suffered from the negotiation between the union and the Secretary of Labor?
The United States Supreme Court reversed the decision, holding that while the union was not exempt from the antitrust laws for entering into an agreement with the large coal operators to secure uniform labor standards throughout the industry, the trial court erred in its jury instructions regarding joint efforts by the union and the large operators to influence the Secretary of Labor with respect to coal purchases by the Tennessee Valley Authority. According to the Court, the lower courts did not take proper account of the doctrine laid down in Eastern R. Conf. v. Noerr Motors, 365 U.S. 127. The Court ruled that Noerr shielded from the Sherman Act, 15 U.S.C.S. § 1 et seq., joint efforts to influence public officials regardless of intent or purpose. Consequently, the jury should have been instructed to exclude any damages suffered as a result of the secretary's determinations.