Matsushita Electric Industrial Co. v. Zenith Radio Corp.

Matsushita Electric Industrial Co. v. Zenith Radio Corp., 475 U.S. 574 (1986), was an antitrust case decided by the Supreme Court of the United States. It raised the standard for surviving summary judgment to unambiguous evidence that tends to exclude an innocent interpretation. Specifically, the issue was whether there was a horizontal "agreement" between Matsushita Electric and other Japanese television manufacturers. The Court held that the evidence must tend to exclude the possibility of independent action to be sufficient to survive summary judgment.

Matsushita v. Zenith Radio Corp.
Argued November 12, 1985
Decided March 26, 1986
Full case nameMatsushita Electric Industrial Co., Ltd. v. Zenith Radio Corp.
Citations475 U.S. 574 (more)
106 S. Ct. 1348; 89 L. Ed. 2d 538
Holding
To survive a motion for a summary judgment, a plaintiff seeking damages for a violation of § 1 of the Sherman Act must present evidence "that tends to exclude the possibility" that the alleged conspirators acted independently, such that the inference of a conspiracy is reasonable in light of the competing inferences of independent action or collusive action that could not have harmed respondents.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William J. Brennan Jr. · Byron White
Thurgood Marshall · Harry Blackmun
Lewis F. Powell Jr. · William Rehnquist
John P. Stevens · Sandra Day O'Connor
Case opinions
MajorityPowell, joined by Burger, Marshall, Rehnquist, O'Connor
DissentWhite, joined by Brennan, Blackmun, Stevens
Laws applied
Sherman Antitrust Act, Rule 56 of the Federal Rules of Civil Procedure

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