J. Truett Payne Co., Inc. v. Chrysler Motors Corp.
United States Supreme Court
451 U.S. 557 (1981)
J. Truett Payne Co., a former Chrysler automobile dealer, sued Chrysler Motors in federal district court, alleging that Chrysler's "sales incentive" program violated the price-discrimination prohibition of section 2(a) of the Clayton Act, as amended by the Robinson-Patman Act. Under the program, Chrysler paid dealers a bonus if they exceeded individually set sales quotas for cars sold at retail or purchased from Chrysler. Payne alleged Chrysler set its quota higher than those of its competitors, so that when Payne fell short of its quota while competitors met their lower ones, Payne received fewer bonuses and effectively paid more for its cars than its competitors did. Payne calculated the resulting price discrimination at $81,248 and claimed the business's going-concern value, before it went out of business, ranged from $50,000 to $170,000. Chrysler maintained the program was nondiscriminatory and caused Payne no injury or competitive harm. The jury awarded Payne $111,247.48 in damages, which the district court trebled.
Whether a plaintiff seeking treble damages under section 4 of the Clayton Act must prove an antitrust violation, a cognizable injury attributable to that violation, and the amount of damages sustained.