Square D Company v. Niagara Frontier Tariff Bureau, Inc. (1985)

Docket
85-21
Decided
1985-01-01

Summary

Question: If prices were fixed in such a way that should be forbidden by the Sherman Act and should not have been approved by the Interstate Commerce Commission, should the carriers be subject to treble damages? Conclusion: No. Justice John Paul Stevens delivered the opinion of the 8-1 majority. The Supreme Court held that the precedent established by the previous decision is relevant to this case because in both cases the rates were approved by the ICC, which meant that the rates were lawful under the Interstate Commerce Act, and the carriers were protected from suits for damages. The Court also held that the recently enacted Reed-Bullwinkle Act did not alter any anti-trust laws applicable to carriers. The legislative history surrounding the Act makes it clear that Congress did not intend to drastically alter existing anti-trust legislation and its judicial interpretation. Justice Thurgood Marshall wrote a dissenting opinion in which he argued that the Court of Appeals opinion provided sufficient analysis as to why the previous precedent should be overruled and that he was persuaded by the analysis.

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