Abraham & Veneklasen Joint Venture v. American Quarter Horse Assoc.
Plaintiffs filed suit against AQHA, alleging violations of the Sherman Act, 15 U.S.C. 1, 2, and Texas antitrust law. Plaintiffs' allegations stemmed from votes by the Stud Book and Registration Committee of the AQHA, which had blocked AQHA registration of horses created through somatic cell nuclear transfer (SCNT or cloning). On appeal, AQHA challenged the district court's denial of its motion for judgment as a matter of law (JMOL). The court concluded that reasonable jurors could not draw any inference of conspiracy from the evidence presented, because it neither tends to exclude the possibility of independent action nor does it suggest the existence of any conspiracy at all. Therefore, the court concluded that the JMOL motion should have been granted in the absence of substantial evidence on the issue of an illegal conspiracy to restrain trade under Section 1 of the Act. Further, the Section 2 claim failed as a matter of law because AQHA is not a competitor in the allegedly relevant market for elite Quarter Horses. Accordingly, the court reversed and rendered judgment for AQHA. View "Abraham & Veneklasen Joint Venture v. American Quarter Horse Assoc." on Justia Law