Gulf Coast Hotel-Motel Ass’n v. Mississippi Gulf Coast Golf Co, et al.

This was an antitrust case involving a dispute between competing programs to sell vouchers for rounds of golf at golf courses along Mississippi's Gulf Coast. The district court granted defendants' motion to dismiss, deciding, in pertinent part, that plaintiff had failed to allege the interstate commerce element of a valid claim under the Sherman Act, 15 U.S.C. 1-7. The court concluded that, if it was true that these hotels and golf courses attracted out-of-state visitors who participated in the voucher program, as the complaint alleged, then there could be no doubt under both the Supreme Court's and this court's jurisprudence that the complaint stated a claim with respect to subject matter jurisdiction. Therefore, because the court found that the district court erred in dismissing the case for lack of subject matter jurisdiction, the court reversed and remanded for further proceedings.