Valley Liquors, Inc. v. Renfield Importers, Ltd.
United States Court of Appeals for the Seventh Circuit
678 F.2d 742 (1982)
Renfield (defendant) switched from a diverse wholesale-distributor network to a restricted one-or-two-distributor system, terminating discount distributor Valley Liquors (plaintiff) and reassigning its territory to two competitors; Valley sued for a preliminary injunction, alleging both a horizontal conspiracy among Renfield and the remaining distributors to raise prices by eliminating Valley's discounting, and an unlawful vertical restraint from the exclusive-distribution switch itself. The district court found Valley hadn't shown a likelihood of success on the merits and denied the injunction; Valley appealed.
Whether an exclusive dealing arrangement is an unlawful vertical restraint in the absence of a net adverse effect on competition.