In re California Gasoline Spot Market Antitrust Litigation

CourtDistrict Court, N.D. California
DecidedMarch 29, 2021
Docket3:20-cv-03131
StatusUnknown

This text of In re California Gasoline Spot Market Antitrust Litigation (In re California Gasoline Spot Market Antitrust Litigation) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re California Gasoline Spot Market Antitrust Litigation, (N.D. Cal. 2021).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 IN RE CALIFORNIA GASOLINE SPOT Case No. 20-cv-03131-JSC

8 MARKET ANTITRUST LITIGATION ORDER RE: DEFENDANTS’ 9 MOTIONS TO STAY AND DISMISS 10 Re: Dkt. Nos. 222, 224 11

12 13 Plaintiffs allege that Defendants entered into horizonal agreements to restrain competition 14 in the spot market for gasoline and gasoline blending components formulated for use in California. 15 Plaintiffs filed a putative class action bringing federal and state antitrust claims as well as state law 16 unfair competition and unjust enrichment claims against SK Trading International Co., Ltd. (“SK 17 Trading”), SK Energy Americas, Inc. (“SK Energy”), Vitol Inc. (“Vitol”), and two individual 18 defendants. Defendants’ joint motion to stay this action pending a related state court action and 19 motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) are now pending before the 20 Court.1 (Dkt. Nos 222, 224.) Having considered the parties’ briefs and having had the benefit of 21 oral argument on January 28, 2021, the Court GRANTS IN PART and DENIES IN PART the 22 motion to dismiss. Plaintiffs’ Sherman Act claim is dismissed as Plaintiffs have not established 23 standing to pursue a claim for injunctive relief and their UCL claim is dismissed as they have 24 failed to show that their legal remedies are otherwise inadequate. The motion to dismiss is 25 otherwise denied. Defendants’ motion to stay is DENIED because Defendants have failed to 26 establish a basis to stay this action under either Colorado River or this Court’s inherent authority. 27 1 BACKGROUND 2 A. Consolidated Class Action Complaint Allegations 3 The gravamen of the CCAC is that SK Trading, SK Energy, and Vitol conspired to 4 “restrain competition in the spot market for gasoline formulated for use in California and in certain 5 gasoline blending components used in that gasoline.” (Consolidated Class Action Complaint 6 (“CCAC”), Dkt. No. 186 at ¶ 1.2) “Defendants’ scheme exploited a disruption in refining capacity 7 that resulted from an incident at the refinery in Torrance, California wherein a cracking unit 8 exploded which impaired the refinery’s ability to refine alkylates from February 2015 through at 9 least June 2016. (Id. at ¶ 3.) The corporate Defendants and their employees—Lucas and 10 Niemann—recognized that the supply disruption provided by the explosion provided them an 11 opportunity to artificially inflate the price of alkylates and thus gasoline (given the relationship 12 between the two). (Id. at ¶ 4.) Defendants negotiated large contracts to supply gasoline and 13 gasoline blending components for delivery in California and entered into agreements with each 14 other to “manipulate the spot market price for refined gasoline and gasoline blending components 15 so that they could realize windfall profits on these contracts.” (Id. at ¶¶ 5-6.) They also entered 16 into profit sharing agreements and agreements to disguise their market interference. (Id.) 17 “Defendants’ repeated and pervasive manipulation of the spot market price caused retail 18 gasoline prices to be higher throughout the Class Period.” (Id. at ¶ 152.) Indeed, California 19 Energy Commission’s Petroleum Market Advisory Committee “concluded that Californians may 20 have paid at least $12 billion in extra gasoline costs due to the ‘unexplained differential’ since the 21 2015 Torrance Refinery explosion.” (Id. at ¶ 155.) Plaintiffs thus allege that they paid more for 22 gasoline as a result of Defendants’ illegal activities. (Id. at ¶ 9.) 23 B. Procedural Background 24 Before this action was filed, the California Attorney General filed a parens patriae action 25 in the San Francisco Superior Court. See The People of the State of California v. Vitol, Inc., et al., 26 Case No. CGC20584456 (S.F. Superior, filed May 4, 2020) (“AG Action”). The AG Action 27 1 includes Cartwright Act and UCL claims. Pacific Wine Distributors, Inc., filed the first action in 2 this District two days after the AG Action was filed, on May 6, 2020. (Dkt. No. 1.) The other 3 named plaintiffs subsequently filed separate actions, each of which was related to this action. The 4 parties thereafter stipulated that all 23 related actions would be consolidated for purposes of trial. 5 (Dkt. Nos. 67, 121, 133, 146, 148, 174.) The Court then appointed Hausfeld and Girard Sharp as 6 co-lead interim class counsel. (Dkt. No. 167.) Shortly thereafter, Plaintiffs filed the now operative 7 Consolidated Class Action Complaint which includes class claims for (1) violation of the Sherman 8 Act, 15 U.S.C. § 1; (2) violation of the Cartwright Act, Cal. Bus. & Prof. Code § 16720; (3) 9 violation of California’s Unfair Competition Law, Cal. Bus. & Prof. Code § 17200; and (4) unjust 10 enrichment. (Dkt. No. 186.) 11 Following a status conference on October 6, 2020, the Court set a phased briefing schedule 12 for Defendants’ forthcoming Rule 12(b) motions with SK Trading’s motion to dismiss for lack of 13 personal jurisdiction and improper venue to be heard before the other Defendants’ Rule 12(b)(6) 14 motion and motion to stay. (Dkt. No. 207.) The motion to dismiss for lack of personal jurisdiction 15 and improper venue under Rule 12(b)(2), (3) came before the Court for hearing on December 16, 16 2020 and the Court subsequently granted Plaintiffs leave to take jurisdictional discovery and 17 deferred ruling on the motion. (Dkt. No. 263.) The Rule 12(b)(6) motion and motion to stay came 18 before the Court for hearing on January 28, 2021. 19 DISCUSSION 20 Defendants move to stay this action in light of the AG’s action in state court and to dismiss 21 each of Plaintiff’s claims under Federal Rule of Civil Procedure 12(b)(6) for failure to state a 22 claim and as barred in part by the statute of limitations. 23 I. MOTION TO DISMISS 24 A. The Cartwright Act 25 The Cartwright Act, Business and Professions Code section 16700 et seq., was “enacted to 26 promote free market competition and to prevent conspiracies or agreements in restraint or 27 monopolization of trade.” Exxon Corp. v. Super. Ct., 51 Cal. App. 4th 1672, 1680 (1997). To state 1 conspiracy; (2) illegal acts done pursuant thereto; and (3) damage proximately caused by such 2 acts.” In re High-Tech Emp. Antitrust Litig., 856 F. Supp. 2d 1103, 1126 (N.D. Cal. 2012) 3 (quoting Kolling v. Dow Jones & Co., 137 Cal. App. 3d 709, 718 (1982)); see also Cty. of 4 Tuolumne v. Sonora Cmty. Hosp., 236 F.3d 1148, 1160 (9th Cir. 2001) (“The analysis under 5 California’s antitrust law mirrors the analysis under federal law because the Cartwright Act, Cal. 6 Bus. & Prof. Code § 16700 et seq., was modeled after the Sherman Act.”). 7 Plaintiffs allege Defendants entered into an agreement that constitutes a per se violation of 8 the Cartwright Act. (CCAC at ¶ 177.) Under the per se rule, certain categories of restraint are 9 treated as “necessarily illegal [which] eliminates the need to study the reasonableness of an 10 individual restraint in light of the real market forces at work.” Leegin Creative Leather Prod., Inc. 11 v. PSKS, Inc., 551 U.S. 877, 886 (2007) (quoting Business Electronics Corp. v. Sharp Electronics 12 Corp., 485 U.S. 717, 723 (1988)).

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In re California Gasoline Spot Market Antitrust Litigation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-california-gasoline-spot-market-antitrust-litigation-cand-2021.