City of Columbia v. Omni Outdoor Advertising, Inc.
E666878
City of Columbia v. Omni Outdoor Advertising, Inc. is a 1991 U.S. Supreme Court antitrust case that refined the scope of immunity for petitioning government under the Noerr-Pennington and state-action doctrines.
Statements (37)
| Predicate | Object |
|---|---|
| instanceOf |
United States Supreme Court case
ⓘ
antitrust case ⓘ |
| areaOfLaw |
competition law
ⓘ
municipal regulation ⓘ |
| citation | 499 U.S. 365 ⓘ |
| clarifiedThat |
Noerr-Pennington immunity applies to efforts to influence municipal action, not only state or federal legislation or adjudication
NERFINISHED
ⓘ
a municipality’s improper motives do not negate state-action immunity if the state policy to displace competition is clearly articulated ⓘ |
| country |
United States of America
ⓘ
surface form:
United States
|
| court | Supreme Court of the United States ⓘ |
| decisionDate | 1991 ⓘ |
| doctrineClarified |
scope of Noerr-Pennington immunity
ⓘ
scope of state-action immunity for municipalities ⓘ |
| fullCaseName | City of Columbia, South Carolina v. Omni Outdoor Advertising, Inc. NERFINISHED ⓘ |
| geographicOrigin | Columbia, South Carolina NERFINISHED ⓘ |
| holding |
Municipalities are immune from federal antitrust liability when acting pursuant to a clearly articulated and affirmatively expressed state policy to displace competition.
ⓘ
The Noerr-Pennington doctrine protects petitioning of government even when the petitioner’s intent is to eliminate competition, absent sham. NERFINISHED ⓘ There is no "conspiracy" exception to state-action immunity for municipalities acting under a clearly articulated state policy. ⓘ |
| impact |
narrowed the circumstances under which antitrust plaintiffs can challenge municipal regulations as conspiracies with private parties
ⓘ
strengthened protections for petitioning activity under the First Amendment in the antitrust context ⓘ |
| issue |
whether a city and a private party can be liable under federal antitrust laws for allegedly anticompetitive zoning and sign regulations adopted under state authority
ⓘ
whether an alleged conspiracy between a municipality and a private party defeats state-action immunity ⓘ whether petitioning a municipality for anticompetitive regulation is protected by Noerr-Pennington ⓘ |
| jurisdiction | federal question jurisdiction ⓘ |
| legalSubject |
Noerr-Pennington doctrine
NERFINISHED
ⓘ
Parker immunity ⓘ antitrust law ⓘ state-action immunity ⓘ |
| majorityOpinionBy | Antonin Scalia NERFINISHED ⓘ |
| petitioner | City of Columbia, South Carolina NERFINISHED ⓘ |
| relatedDoctrine |
Eastern Railroad Presidents Conference v. Noerr Motor Freight, Inc.
NERFINISHED
ⓘ
Parker v. Brown NERFINISHED ⓘ United Mine Workers v. Pennington NERFINISHED ⓘ |
| respondent | Omni Outdoor Advertising, Inc. NERFINISHED ⓘ |
| result | judgment in favor of the City of Columbia and the private advertiser on antitrust claims ⓘ |
| subjectMatter | billboard and outdoor advertising regulation ⓘ |
| vote | 6–3 ⓘ |
| yearDecided | 1991 ⓘ |
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.