Robinson-Patman Applied to Customer-Specific Bid Discounts

Volvo Trucks North America, Inc. v. Reeder-Simco GMC, Inc.

The United States Supreme Court recently announced its decision in Volvo Trucks North America, Inc. v. Reeder-Simco GMC, Inc., No. 04-905 (Jan. 10, 2006), the Roberts’ Court’s first foray into antitrust law. Interpreting the Robinson-Patman Act’s prohibition on price discrimination, the decision provides helpful guidance to companies that sell through independent dealers, especially those companies that offer negotiated discounts to their dealers in an effort to aid those dealers in competing with rival manufacturers’ dealers. The decision emphasized the Court’s continuing commitment to interpreting the federal antitrust laws in a manner that promotes interbrand competition, rather than protects individual competitors. Foley attorneys G. Michael Halfenger and Jon P. Christiansen represented several manufacturing associations that filed amicus briefs supporting Volvo Truck’s request for Supreme Court review and for reversal of