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Antitrust Keyed to Morgan, 7th Ed.
Southern Motor Carriers Rate Conference v. United States
Citation:
471 U.S. 48, 105 S. Ct. 1721, 85 L. Ed. 2d 36 (1985)Facts
In North Carolina, Georgia, Mississippi, and Tennessee, Public Service Commissions regulated intrastate transportation rates for motor common carriers. Carriers were required to submit proposed rates to the relevant Commission for approval. All four states allowed, but did not require, common carriers to agree on rate proposals prior to their joint submission to the regulatory agency. The defendants, Southern Motor Carriers Rate Conference (SMCRC) and North Carolina Motor Carriers Association (NCMCA), were private associations composed of motor common carriers operating in these states. They facilitated collective ratemaking by their members, who would jointly establish rates to propose to the state regulatory commissions. Members were not bound by the joint proposals and could submit independent rate proposals. The United States filed an antitrust action against the rate bureaus, alleging that their collective ratemaking activities violated Section 1 of the Sherman Act. The defendants claimed immunity under the state-action doctrine established in Parker v. Brown.
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