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Antitrust Keyed to Sullivan, 8th Ed.
Missouri v. National Organization for Women, Inc.
Citation:
620 F.2d 1301 (1980)Facts
The National Organization for Women actively engaged in an economic boycott campaign as part of a larger convention boycott movement directed at states that had not ratified the proposed Equal Rights Amendment. The boycott took place in an essentially political context with the sole purpose and goal of achieving ERA ratification. NOW’s motivation was twofold: to make a symbolic gesture and to attract public attention and visibility to the ratification issue. NOW also intended that the adverse economic impact on those who would profit from conventions would cause them to influence their legislators to support ERA ratification. The boycott was not intended as punishment for Missouri’s past failure to ratify, and NOW was not motivated by any anticompetitive purpose. The participants were not in a competitive relationship with Missouri, which suffered economic losses as a result. Missouri’s convention industry businesses suffered economic injury with adverse effects extending throughout the state’s economy. NOW’s target was the state legislature, the supreme policy-making body of the state.
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