LEH v. GENERAL PETROLEUM CORP.

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Case Basics
Docket No. 
4
Petitioner 
Marc D. Leh
Respondent 
General Petroleum Corp.
Opinion 
Advocates
(for the petitioner)
(for the respondent)
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Facts of the Case 

The Clayton Antitrust Act (“Clayton Act”) was enacted by Congress in 1914 to prevent anticompetitive practices in business. Section 5(b) of the Clayton Act halted the running of the statute of limitations on pending claims arising from the act. It also specified a four-year statute of limitations for these causes of action.

On September 28, 1956, Marc D Leh brought an action against General Petroleum Corportation and five other petroleum manufacturers alleging injury to his business caused by a conspiracy or combination to exclude Leh from engaging in wholesale distribution of gasoline in Southern California. He alleged that this conspiracy began in 1948; all parties agreed that Leh’s right to initiate a cause of action began in February of 1954. Leh anticipated a statute of limitations problem under California law, as California’s Code of Civil Procedure specified a one-year statute of limitations for penal causes of action, in contrast to the Clayton Act’s four-year limit. Hence, Leh cited to United States v. Standard Oil, in which the United States alleged a conspiracy to control prices among a nearly identical set of defendants and successfully applied the Clayton Act’s longer limit.

District court Judge William Mathes ruled in favor of General Petroleum, holding that the tripling of damages was a penalty, and was thus barred by the statute of limitations under California law. The court also held that the Clayton Act did not apply to the claim --distinguishing on the facts from Standard Oil-- primarily because Leh did not allege that the defendants combined to control prices, did not name the same set of defendants, and did not allege a similar period of conspiracy. Judge Stanley Barnes of the U.S. Court of Appeals, Ninth Circuit, affirmed. Judge Barnes affirmed the lower court’s interpretation of California law, and that the application of the Clayton Act used in Standard Oil did not apply here because the facts were not similar enough to justify collateral estoppel.

Question 

Is Leh’s claim similar enough to that made by the government in Standard Oil to justify his use of collateral estoppel? Was Leh’s claim valid because the Clayton Act suspended the running of the statute of limitations?

Conclusion 
Decision: 7 votes for Leh, 0 vote(s) against
Legal provision: Clayton

Yes and yes. Justice Thomas White, writing for a unanimous Court, held that Leh is not required to allege equivalent means, objectives and conspiracy to rely on Standard Oil. Relying on the Court’s 1965 decision in Minnesota Mining & Mfg. Co. v. New Jersey Wood Finishing Co., Justice White emphasized giving effect to the broad terms of the Clayton Act and Congress’ belief that antitrust litigation is one of the surest weapons for effective enforcement of antitrust laws. He noted that six of the seven defendants were named in both Leh’s claim and the United States’ in Standard Oil, and that the United States similarly alleged an intention to eliminate the competition of independent refiners. Thus, Leh’s pending case halted the tolling of the statute of limitations under the Clayton Act, and his claim was still valid.

Justices John Harlan and Abraham Fortas took no part in the consideration or decision of this case.

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LEH v. GENERAL PETROLEUM CORP.. The Oyez Project at IIT Chicago-Kent College of Law. 19 June 2014. <http://www.oyez.org/cases/1960-1969/1965/1965_4>.
LEH v. GENERAL PETROLEUM CORP., The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1960-1969/1965/1965_4 (last visited June 19, 2014).
"LEH v. GENERAL PETROLEUM CORP.," The Oyez Project at IIT Chicago-Kent College of Law, accessed June 19, 2014, http://www.oyez.org/cases/1960-1969/1965/1965_4.