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Keywords

contracttortplaintiffdefendantdamagestrustleasecorporationantitrusttreble damagespiracy

contracttortplaintiffdefendantdamagestrustleaseantitrusttreble damagespiracy

Related Cases

Fishman v. Estate of Wirtz, 807 F.2d 520, 55 USLW 2317, 1986-2 Trade Cases P 67,356, 1987-1 Trade Cases P 67,536

Facts

The case involves an antitrust action brought by Illinois Basketball, Inc. (IBI) and its president Marvin Fishman against the successful bidder Chicago Professional Sports Corporation (CPSC) and its stockholders, as well as the owner of the Chicago Stadium. IBI had negotiated to purchase the Chicago Bulls basketball team, but the defendants engaged in actions that effectively blocked IBI from acquiring a necessary lease for the stadium, which was crucial for NBA approval of the sale. The court found that the defendants violated antitrust laws by refusing to lease the stadium to IBI and participating in a conspiracy to prevent IBI from obtaining the franchise.

Issue

Did the defendants' refusal to lease the Chicago Stadium to IBI and their lobbying efforts constitute violations of the Sherman Act and Illinois law?

Rule

The Sherman Act prohibits contracts, combinations, or conspiracies in restraint of trade. A refusal to deal with a competitor can violate antitrust laws if it constitutes an unlawful exclusion from a market. The 'essential facilities doctrine' requires that a firm controlling an essential facility must provide access to competitors on nondiscriminatory terms. Additionally, tortious interference with prospective advantage under Illinois law requires proof of intentional interference that prevents a plaintiff from realizing a reasonable expectation of entering a business relationship.

Analysis

The court analyzed the defendants' actions under the Sherman Act, determining that their refusal to lease the Chicago Stadium to IBI effectively eliminated competition for the basketball franchise. The court found that the stadium was an essential facility that IBI needed to compete. The defendants' lobbying efforts to influence the NBA's decision against IBI were also scrutinized, leading to the conclusion that these actions constituted a conspiracy to restrain trade. The court ruled that the defendants' conduct was not only anticompetitive but also tortious under Illinois law.

Conclusion

The court affirmed that the defendants violated the Sherman Act by refusing to lease the stadium to IBI and engaged in tortious interference with IBI's prospective advantage. The case was remanded for recalculation of damages.

Who won?

Illinois Basketball, Inc. (IBI) prevailed in the antitrust action against the defendants. The court found that the defendants' refusal to lease the Chicago Stadium to IBI constituted a violation of the Sherman Act, as it effectively eliminated competition for the basketball franchise. The court also ruled that the defendants' actions amounted to tortious interference with IBI's prospective advantage, as they intentionally blocked IBI's reasonable expectation of acquiring the franchise. The court's decision to award treble damages to IBI underscored the seriousness of the antitrust violations committed by the defendants.

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