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Antitrust Keyed to Areeda, 8th Ed.
Columbia v. Omni Outdoor Advertising, Inc.
Citation:
499 U.S. 365 (1991)Facts
Columbia Outdoor Advertising (COA) had dominated the billboard market in Columbia, South Carolina since the 1940s, controlling over 95% of the market by 1981. The company maintained close relationships with city officials, including personal friendships and campaign contributions. In 1981, Omni Outdoor Advertising, a Georgia corporation, began erecting billboards in Columbia. COA responded by intensifying its own billboard construction, allegedly engaging in anticompetitive private actions, and lobbying city officials for restrictive billboard ordinances. In 1982, the city council passed a series of ordinances restricting billboard construction. After a state court invalidated an initial ordinance, the city enacted a new ordinance limiting the size, location, and spacing of billboards, which benefited COA’s established position while hindering Omni’s ability to compete. Omni filed suit, claiming the ordinances resulted from an anticompetitive conspiracy between city officials and COA. A jury found both defendants liable for antitrust violations, but the District Court granted judgment notwithstanding the verdict, which the Court of Appeals reversed.
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