In Re: Domestic Airline Travel Antitrust Litigation

CourtDistrict Court, District of Columbia
DecidedSeptember 29, 2025
DocketMisc. No. 2015-1404
StatusPublished

This text of In Re: Domestic Airline Travel Antitrust Litigation (In Re: Domestic Airline Travel Antitrust Litigation) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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In Re: Domestic Airline Travel Antitrust Litigation, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

IN RE DOMESTIC AIRLINE TRAVEL ANTITRUST LITIGATION

MDL Docket No. 2656 Misc. No. 15-1404 (CKK)

This Document Relates To:

ALL CASES

MEMORANDUM OPINION (September 29, 2025)

This multidistrict litigation involves claims that, during the period January 2009 through mid-2015, four major airlines — Southwest Airlines Co. (“Southwest”), American Airlines, Inc. (“American”), Delta Air Lines, Inc. (“Delta”), and United Airlines, Inc. (“United”) — colluded to limit capacity on their respective airlines in a conspiracy to fix, raise, maintain, and/or stabilize prices for domestic flights in violation of Sections 1 and 3 of the Sherman Antitrust Act (15 U.S.C. §§ 1, 3), and that Plaintiff Class Members paid artificially inflated ticket prices as a result of this alleged antitrust violation. On May 13, 2019, after holding a fairness hearing, this Court issued an [373] Order Approving Plaintiffs’ Motion for Final Approval of Settlement Agreements with Settling Defendants’ Southwest and American, accompanied by a [374] Memorandum Opinion which explained the rationale for the Court’s decision. This litigation continued to proceed regarding Plaintiffs’ claims against Non-Settling Defendants’ Delta and United (hereinafter referred to collectively as “Defendants”). The parties engaged in discovery, and Defendants filed extensive summary judgment motions, with hundreds of exhibits.

On September 5, 2023, this Court issued its [615] Memorandum Opinion and [614] Order

1 denying the motions for summary judgment filed by Defendants Delta and United.' In its discussion of the legal standard, the Court acknowledged that in order to survive Defendants’ motion for summary judgment, Plaintiffs had to prove a “pattern of parallel behavior” as well as “the existence of one or more plus factors that tends to exclude the possibility that the alleged conspirators acted independently.” Mem. Op., ECF No. 615, at 18 (citations omitted). Before beginning its analysis of the arguments made by the parties, the Court outlined the arguments presented by Defendants:

(A) there is no evidence of parallel capacity behavior because (1) Defendants’ domestic

system capacity changes differed substantially and sometimes exceeded GDP; (2)

Defendants’ capacity growth rates did not deviate from historical patterns, (3) Moving

Defendants’ competition at the route level and in other hubs defies an inference of

conspiracy; (4) Plaintiffs have no evidence of punishment for Moving Defendants’ [in this

case, Delta’s] above-GDP capacity growth; (5) there is no evidence of Delta/Defendants engaging in private conspiratorial communications; and (B) Moving Defendants had legitimate, non-conspiratorial reasons for their capacity actions and statements about capacity, which do not exclude the possibility of independent action and unilateral self- interest; and (C) Plaintiffs’ plus factors are equally consistent with independent action because they hold true for other airlines.

Id. at 20.

This Court undertook an analysis of these arguments (in the same order in which the arguments were presented by Defendants), and the Court considered also Plaintiffs’ counterarguments, as well as the exhibits relied upon by both sides. At the end of its 70-page opinion, the Court concluded that “Plaintiffs ha[d] presented enough evidence demonstrating a

pattern of parallel behavior and the existence of one or more plus factors (that tend to exclude the

possibility that Defendants acted independently) to survive Moving Defendants’ motions for

' The Court incorporates by references its [615, redacted public version] Memorandum Opinion. 2 summary judgment.” Mem. Op., ECF No. 615, at 70.

Pending before this Court are Defendants’ [617] Motion for Certification for Interlocutory Appeal and [618] Motion for Reconsideration of this Court’s Order denying summary judgment. Defendants’ motion is based on their allegation that “the Court made two legal rulings that directly conflict with clear legal precedent from every Circuit that has considered the issues raised in this motion,” Defs.’ Mot., ECF No. 617, at 7, namely (as stated by Defendants), (1) that “parallel actions by competitors (in this case, airlines) to increase price or limit output can by itself create an inference of a conspiracy,” id. at 8, and (2) that “Defendants did not have a legitimate business interest in making public statements to investors about their ‘forward-looking capacity plans’ because the statements were useless to consumers.” Jd. at9. In connection with the second alleged ruling, Nasdaq, Inc. (“Nasdaq”) and the New York Stock Exchange, LLC. (“NYSE”) (collectively, the “non-parties”) filed their [621] Motion for Leave to File Amicus Brief, whereby they seek “to be heard in this matter to stress that, . . ., public companies have legitimate business reasons for

disclosing information to investors about their forward-looking business plans and prospects, even

2 In connection with this Opinion, the Court considered: (1) Non-Settling Defendants’ [617] Motion for Certification for Interlocutory Appeal, which is consolidated with its Motion for Reconsideration (although the reconsideration motion is assigned ECF No. 618, for docketing purposes only) (“Defs.’ Mot.”); (2) Plaintiffs’ [619] Opposition to Defendants’ Motion (“Pls.’ Opp’n”); (3) Defendants’ [620] Reply to Plaintiffs’ Opposition (“Defs.’ Reply”); (4) Non-parties’ New York Stock Exchange and Nasdaq, Inc.’s [621] Motion for Leave to File Amicus Brief (“Amicus Mot.”); (5) Plaintiffs’ [624] Opposition to the Amicus Motion (“Amicus Opp’n”); (6) United’s [639] Notice of Supplemental Authority (“Supp. 1”); (7) Plaintiffs’ [640] Response to Supplement 1(“Resp. to Supp. 1”); (8) Delta’s [641] Notice of Supplemental Authority (“Supp. 2”); (9) Plaintiffs’ [642] Response to Supplement 2 (“Resp. to Supp. 2”); and (10) the record in this case. In an exercise of its discretion, the Court finds that holding oral argument in this action would not be of assistance in rendering a decision. See LCvR 7(f).

3 if that information is not useful to end consumers, such as, in this case, airline passengers.” Amicus Mot., ECF No. 621, at 3.

Upon consideration of the pending motions, and for the reasons set forth herein, this Court DENIES Defendants’ [617] Motion for Certification for Interlocutory Appeal and [618] Motion for Reconsideration and DENIES the non-parties’ [621] Motion for Leave to File Amicus Brief. Below, the Court will address each motion, in turn. A separate Order accompanies this Memorandum Opinion.

I. Motion for Certification for Interlocutory Appeal

A. Legal Standard

Pursuant to 28 U.S.C. § 1292(b), a District court may certify an order for immediate appeal if: (1) it involves a controlling question of law; (2) a substantial ground for difference of opinion exists; and (3) immediate appeal would materially advance the ultimate termination of the case. In re Rail Freight Fuel Surcharge Antitrust Litig. (“Rail Freight’), Civ. No. 11-1049 (PLF), 2021 WL 2433737, *4 (D.D.C. June 15, 2021); Citizens for Resp.& Ethics in Washington v. Am. Action Network (“CREW”), 415 F. Supp. 3d 143, 144-45 (D.D.C. 2019) (citation and quotation marks omitted). This provision represents a departure from “the basic policy of postponing appellate review until after the entry of a final judgment,” Coopers & Lybrand v. Livesay, 437 U.S. 463

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