United States v. Waste Management, Inc.

United States Court of Appeals for the Second Circuit

743 F.2d 976 (1984)

Relevant factsFree

Waste Management, Inc. (WMI) (defendant) acquired a competitor, EMW Ventures, giving WMI a 48.8 percent share of the trash-collection market in Dallas County. The government (plaintiff) sued under the Clayton Act, and the district court treated that market share as a prima facie case of illegality; while the court found market entry was easy for both new entrepreneurs and out-of-area trash haulers, it concluded ease of entry could not rebut the presumption of illegality and ruled the merger unlawful. WMI and EMW appealed.

IssueFree

Whether ease of entry into the relevant market can rebut a prima facie showing that a merger is illegal under the Clayton Act.

Holding & reasoning

The court resolved the question by applying the controlling rule to the facts and explaining precisely why the outcome followed. Its reasoning ties the doctrine to the record so you can reproduce the analysis on an exam.

Procedural history, concurrence & dissent

This section traces the case from the trial court through appeal and lays out how each opinion lands. Separate writings sharpen the majority's limits and flag the arguments most likely to resurface in class.

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