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GRSM Chicago Team Wins Eighth Circuit Victory Upholding Dismissal of Price-Fixing and Boycott Claims

Gordon Rees Scully Mansukhani Chicago Partners Gretchen Harris Sperry and Brian Roth secured the affirmance of a district court dismissal with prejudice on behalf of GRSM’s client, the largest member-owned crop protection distribution entity in the United States, in multidistrict antitrust litigation brought by putative classes of purchasers of seeds and crop-protection products, including fungicides, herbicides, and insecticides.

The plaintiffs alleged that manufacturers, wholesalers, and retailers conspired to fix prices and boycott competing electronic platforms in the crop-input market, thereby forcing the farmers to pay higher prices. The plaintiffs sought injunctive relief and damages for the defendants’ alleged violations of Section 1 of the Sherman Antitrust Act, the Racketeer Influenced and Corrupt Organizations Act (RICO), and various state laws.

The U.S. District Court for the Eastern District of Missouri granted the defendants’ joint motion to dismiss the consolidated complaints for failure to state a claim. On the antitrust claim, the court concluded that the plaintiffs did not adequately allege parallel conduct by the defendants and dismissed the claim with prejudice. The court also dismissed the RICO claim with prejudice and declined to exercise supplemental jurisdiction over the plaintiffs’ state law claims.

The plaintiffs challenged only the dismissal of the antitrust claim on appeal. The U.S. Court of Appeals for the Eighth Circuit affirmed the district court’s decision, holding that plaintiffs failed to plausibly allege an agreement or parallel conduct sufficient to state a claim under Section 1 of the Sherman Act.

Read more about this case in the court opinion.