Texas Industries, Inc. v. Radcliff Materials, Inc.

Brief Fact Summary.

Petitioner was accused of conspiring with other concrete companies to raise prices. Petitioner filed a third-party complaint against Respondents for their role in the conspiracy.

Synopsis of Rule of Law.

Federal courts do not have the power to exercise a right of contribution for antitrust violations, either through federal antitrust laws or federal common law.

Facts.

Petitioner, a manufacturer and seller of concrete, was sued in federal district court by Wilson P. Abraham Construction Co., a concrete purchaser, for conspiracy to raise prices in violation of § 1 of the Sherman Act. Petitioner then filed a third-party complaint against the companies Petitioner allegedly conspired with to enforce a right of contribution.

Issue.

Do federal court have power to exercise a right of contribution for antitrust violations, either through federal antitrust laws or the power of federal courts to formulate limited areas of federal common law?

Held.

No, federal courts do not have the power to exercise a right of contribution for antitrust violations, either through federal antitrust laws or federal common law. The decision is reversed.

Discussion.

The Court determines that federal antitrust laws do not create a right of contribution and the federal courts to do not have the power to formulate a right of contribution. Federal courts have the power to create limited areas of federal common law when (1) it is necessary to protect uniquely federal interests or (2) Congress has given the courts power to develop the law. Right of contribution among antitrust violators is not a unique federal interest and Congress did not give courts the right to formulate remedies under the Sherman Act.