Volvo Trucks North America, Inc. v. Reeder-Simco GMC, Inc.

Volvo Trucks North America, Inc. (the defendant) manufactured heavy-duty trucks and sold the trucks at a wholesale discount to dealers through a bidding process. The dealers would then sell the trucks to retail customers in exclusive geographic territories. The defendant sought to reduce the number of dealers it sold its trucks to from 146 to 75. Reeder-Simco GMC, Inc. (the plaintiff) was a heavy-duty-truck dealer that sold the defendant’s trucks. The plaintiff learned that the defendant gave a wholesale discount to another dealer that was greater than the discount usually given to the plaintiff. Accordingly, the plaintiff brought suit, alleging a violation of the Robinson-Patman Act. At trial, the plaintiff provided purchase-to-purchase comparisons, offer-to-purchase comparisons, and head-to-head comparisons in order to show that its discounts were less than that of its competitors. In one head-to-head bidding competition, both Volvo dealers lost the bid. In the other, Volvo’s discount offers to the winning bidder and plaintiff were initially the same, but the defendant ultimately increased its discount offer to the winning bidder after it won the bid.

The United States Court of Appeals for the Eighth Circuit affirmed the trial court’s judgment in favor of the plaintiff. The defendant appealed, and the United States Supreme Court granted certiorari.