Columbia v. Omni Outdoor Advertising, Inc.
United States Supreme Court
499 U.S. 365 (1991)
Columbia Outdoor Advertising (COA) (defendant), a longtime local billboard company with strong ties to city officials, faced new competition when Omni Outdoor Advertising (plaintiff) entered the market; after COA met with city officials, Columbia, South Carolina (defendant) enacted an ordinance restricting billboard location, dimensions, and apportionment that disproportionately burdened Omni's ability to compete since COA already had existing billboards in place. Omni sued under the Sherman Act, alleging the city and COA had conspired anticompetitively; a jury found for Omni, the district court overturned the verdict on state-action immunity grounds, and the court of appeals reversed, reinstating the verdict.
Whether the state-action doctrine immunizing conduct from antitrust liability is subject to a conspiracy exception.