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Monsanto Co. v. Spray-Rite Service Corp.
Supreme Court of the United States (1984) | 465 U.S. 752
TL;DR: A terminated discount distributor sued a manufacturer, alleging a price-fixing conspiracy. The Supreme Court held that to prove a conspiracy, evidence must go beyond mere complaints from other distributors and tend to exclude the possibility that the manufacturer acted independently.
Legal Significance: Establishes the evidentiary standard for proving a vertical price-fixing conspiracy under Sherman Act § 1. A plaintiff must present evidence that "tends to exclude the possibility" of independent action; evidence of termination following competitor complaints is, by itself, insufficient to infer a conspiracy.