Hasbrouck v. Texaco, Inc.

634 F. Supp. 34, 1985 U.S. Dist. LEXIS 16110
CourtDistrict Court, E.D. Washington
DecidedSeptember 11, 1985
DocketC-76-027-JLQ
StatusPublished
Cited by6 cases

This text of 634 F. Supp. 34 (Hasbrouck v. Texaco, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hasbrouck v. Texaco, Inc., 634 F. Supp. 34, 1985 U.S. Dist. LEXIS 16110 (E.D. Wash. 1985).

Opinion

*36 MEMORANDUM OPINION AND ORDER DENYING MOTION FOR JNOV OR NEW TRIAL

QUACKENBUSH, District Judge.

AS SCHEDULED, this matter came on for oral argument in Spokane, Washington on August 14, 1985. Plaintiffs were represented by Robert Whaley and Lucinda Whaley. William Fremming Nielsen, Randall Robinson, Mark Litvack and Ira Sacks appeared on behalf of the defendants.

Upon consideration of the record and the oral presentations of counsel, the court rules as follows: defendant’s motion for judgment notwithstanding the verdict or a new trial (Ct.Ree. 739) is DENIED.

DISCUSSION

A. Judgment Notwithstanding The Verdict:

Pursuant to Fed.R.Civ.P. 50(b), Texaco asks this court to set aside the verdict and enter judgment in accordance with its motion for directed verdict. 1 Such a motion may be granted only if the jury's verdict is not supported by substantial evidence. Los Angeles Memorial Coliseum Com’n v. National Football League, 726 F.2d 1381, 1392 (9th Cir.1984). Stated another way, a judgment notwithstanding the verdict is appropriate when the evidence permits only oné reasonable conclusion as to a verdict and the jury’s verdict is inconsistent with that conclusion. See Walker v. KFC Corp., 728 F.2d 1215, 1223 (9th Cir.1984). In making that analysis, this court is prohibited from considering witness credibility or weighing the evidence but must view the evidence in the light most favorable to the plaintiffs. Los Angeles Memorial Coliseum Com’n v. National Football League, 726 F.2d at 1392. Applying those principles to each of the four grounds asserted in defendant’s motion, the court concludes the verdict must stand.

1. Price differentials as “functional discounts”:

A “functional discount” is a traditional technique used in business pricing practices. Sawyer, Business Aspects of Pricing Under the Robinson-Patman Act (1963). A functional discount occurs where a buyer is permitted to purchase a product for a lower price than another buyer because of the different levels of distribution occupied by the buyers or because the buyers perform different functions in the seller’s marketing system. 2 The primary justification for the discount is to compensate the buyer for its cost of performing functions ordinarily performed by the seller. 3 *37 Generally, functional discounts do not trigger Robinson-Patman Act liability either because the buyer who receives the discount and the buyer who does not are on different trade levels (and therefore are not competitors) or because the discount merely offsets the competing buyer’s additional costs incurred in performing the seller’s functions. In other words, if the buyers do not function at the same level the requisite “competitive injury” is unlikely. Similarly, if the discount merely offsets the buyer’s additional costs, it is unlikely the buyer’s condition would be enhanced enough to cause an injury to competition. Thus, the critical question in determining the legality of a functional discount is whether the price differential has an adverse effect on competition; if it does, and conventional defenses are absent, the discount violates the Act. 3 Kintner & Bauer, Federal Antitrust Law, 308 (1983) (“underlying inquiry ...: is there injury to competition?”); Antitrust Section, Monograph No. 4, The Robinson-Patman Act: Policy and Law, Volume 1 54 (1980) (legality of functional discounts “depends upon the absence of adverse competitive effects”); Calvani, Functional Discounts Under the Robinson-Patman Act, 17 B.C. Indus. & Comm.L.Rev. 543, 546 (1976) (legitimacy of functional discounts “depends on the absence of an anti-competitive effect”); Mueller Company v. Federal Trade Commission, 60 F.T.C. 120, 129 (1962), aff'd 323 F.2d 44 (7th Cir.1963), quoting General Foods Corporation, 52 F.T.C. 798 (1956) (the Robinson-Patman Act permits “lower prices to one functional class as against another, provided that injury to commerce as contemplated by the law does not result ...”); Doubleday and Company, Inc., 52 F.T.C. 169, 207 (1955) (“traditional [functional] discounts ... remained lawful under the Robinson-Patman Act unless engendering adverse effects on competition ...”); cf. FLM Collision Parts, Inc. v. Ford Motor Co., 543 F.2d 1019, 1027 (2nd Cir.1976), cert. denied, 429 U.S. 1097, 97 S.Ct. 1116, 51 L.Ed.2d 545 (1977) (“[w]e do not suggest or imply that ... a price discount to ... wholesalers ... which has the purpose or effect of defeating the objectives of the Act” is beyond the scope of the Act).

Even without viewing the evidence in the light most favorable to the plaintiffs, the preponderance of the evidence produced in this case demonstrated that Texaco’s functional discounts adversely affected competition. That result was brought about primarily by two reasons. First, since Texaco engaged in dual distribution, i.e., sold to both retailers and distributors, the plaintiffs and the favored buyers were not always in competition. 4 That absence of competition, however, does not negate competitive injury, where, as here, the disfavored buyer competes with the favored buyer’s customers. As the Supreme Court recently confirmed, a Robinson-Patman Act violation may occur even though the favored and disfavored buyers are not competitors. Falls City Industries v. Vanco Beverage, Inc., 460 U.S. 428, 103 S.Ct. 1282, 75 L.Ed.2d 174 (1983) (competition was between customers of favored buyers and customers of disfavored buyers). The record in this case contains substantial evidence that the favored purchasers’ (or their customers’) lower retail prices attracted customers away from the plaintiffs and that the lower prices were the *38 major reason for the diverted sales. Such evidence more than establishes injury to competition. Falls City Industries v. Vanco Beverage, Inc., 460 U.S. at 437-38, 103 S.Ct. at 1290-91, citing J. Truett Payne Co. v. Chrysler Motors Corp., 451 U.S. 557, 561-62,101 S.Ct. 1923, 1926-27, 68 L.Ed.2d 442 (1981).

Secondly, the functional discounts negatively affected competition because they were, in part, reflected in the favored purchasers’ (or their customers’) retail prices.

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Bluebook (online)
634 F. Supp. 34, 1985 U.S. Dist. LEXIS 16110, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hasbrouck-v-texaco-inc-waed-1985.