Bell Atlantic v. Twombly
United States Supreme Court
550 U.S. 544 (2007)
William Twombly (plaintiff) sued Bell Atlantic Corporation and other local telephone companies (defendants) on behalf of telecom subscribers, alleging the companies violated Section 1 of the Sherman Act by conspiring through "conscious parallelism" to block competition from new telecom entrants and to avoid competing with each other, each dominating its own regional market. Twombly's complaint offered no direct evidence of an actual agreement among the companies, relying instead on their parallel business conduct. The district court dismissed the complaint under Rule 12(b)(6) for failing to state a claim; the Second Circuit reversed, and the Supreme Court granted certiorari.
Whether a complaint states a claim under section 1 of the Sherman Act only if it contains enough factual matter to plausibly suggest that an agreement existed, and whether proving an antitrust conspiracy requires evidence that tends to exclude the possibility that the defendants acted independently.