Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007)
Primary Holding
A complaint alleging a violation of §1 of the Sherman Act must include sufficient factual context to suggest an agreement among defendants, rather than merely alleging parallel conduct; otherwise, it is subject to dismissal.
In the case of Bell Atlantic Corp. v. Twombly, the Supreme Court decided that when people claim companies are working together to harm competition, they need to provide clear evidence of that agreement, not just say the companies acted similarly. This matters because it sets a higher standard for proving cases of unfair business practices, which can help prevent frivolous lawsuits that could burden companies and ultimately lead to higher prices for consumers. If you believe companies are colluding in a way that harms you as a consumer, this case is relevant because it means you need to gather solid proof of their agreement, not just their similar actions.
AI-generated plain-language summary to help you understand this case
Consumers with telephone and internet subscriptions brought an antitrust claim against local telephone companies, alleging that the companies had arranged not to compete with each other and had attempted to exclude potential competitors in a way that gave them a monopoly over the market. The complaint was dismissed for failure to state a claim, but it was reinstated on appeal.
Whether a complaint alleging violations of §1 of the Sherman Act can survive a motion to dismiss when it claims that major telecommunications providers engaged in parallel conduct unfavorable to competition, absent factual context suggesting an agreement rather than identical, independent action.
The judgment is reversed.
Areas like antitrust may require more specific facts in the pleadings, since there is a greater potential for abuse, but technically there is no heightened pleading requirement in these cases. The claim for relief must be more than merely conceivable for the complaint to survive.
- Court
- Supreme Court
- Decision Date
- November 27, 2006
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Souter
- Damages Awarded
- N/A
- Data Quality
- high
Sprint Communications Co. v. APCC Services, Inc., 554 U.S. 269 (2008)
Consumer WonAn assignee of a legal claim for money owed has standing to pursue that claim in federal court, even when the assignee has promised to remit the proceeds of the litigation to the assignor.
Global Crossing Telecommunications, Inc. v. Metrophones Telecommunications, Inc., 550 U.S. 45 (2007)
Consumer WonThe Federal Communications Commission's interpretation of §201(b) of the Communications Act, which requires long-distance carriers to compensate payphone operators for calls made from payphones, is a lawful application of the statute, and §207 authorizes payphone operators to bring federal lawsuits against carriers that refuse to pay such compensation.
Credit Suisse Securities (USA) LLC v. Billing, 551 U.S. 264 (2007)
Consumer LostThe Supreme Court held that federal securities laws implicitly preclude the application of antitrust laws to the conduct of underwriters in the context of initial public offerings, as there is a "plain repugnancy" between the two legal frameworks regarding the practices alleged in the case.
Stoneridge Investment Partners, LLC v. Scientific-Atlanta, Inc, 552 U.S. 148 (2008)
Consumer LostThe Supreme Court held that investors cannot impose liability on third-party companies under §10(b) of the Securities Exchange Act and SEC Rule 10b-5 if they did not rely on the statements or representations made by those companies, even if the companies engaged in deceptive practices that contributed to the misleading financial statements of the primary defendant.