Rhett G. Campbell, Tr., Joseph C. Canizaro, Intervenor-Appellant v. Wells Fargo Bank, N.A., 781 F.2d 440 (5th Cir. 1986). · Go Syfert
Rhett G. Campbell, Tr., Joseph C. Canizaro, Intervenor-Appellant v. Wells Fargo Bank, N.A., 781 F.2d 440 (5th Cir. 1986). Cases Citing This Book View Copy Cite
“it may very well be that, under general principles of standing, most non-customer injuries will be too remote to furnish a basis for recovery under the act.”
311 citation events (230 in the last 25 years) across 30 distinct courts.
Strongest positive: Stefiuk v. First Union National Bank of Florida (flsd, 1999-06-29)
Treatment trajectory · 1986 → 2026 · click a year to view as-of
1986 2006 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
discussed Cited as authority (verbatim quote) Stefiuk v. First Union National Bank of Florida (2×) also: Cited "see, e.g."
S.D. Fla. · 1999 · signal: see · quote attribution · 1 verbatim quote · confidence high
it may very well be that, under general principles of standing, most non-customer injuries will be too remote to furnish a basis for recovery under the act.
cited Cited as authority (rule) Irrion Conaler, et al. v. Louisiana Department of Public Safety and Corrections, Office of Juvenile Justice
E.D. La. · 2026 · confidence medium
Doc. 17 at p. 5. 57 Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986).
cited Cited as authority (rule) In re: Richmont Capital Partners VII, LP
Bankr. N.D. Tex. · 2026 · confidence medium
Dist., 938 F.3d 724, 735 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) In re: With Purpose, Inc.; Scott M. Seidel, Trustee v. Winston & Strawn LLP, and Michael Blankenship
Bankr. N.D. Tex. · 2026 · confidence medium
Dist., 938 F.3d 724, 735 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) Charles Brower, Jr. v. Brandon Leblanc, et al.
E.D. La. · 2026 · confidence medium
Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986).
cited Cited as authority (rule) Randy Bordelon, et al. v. Jefferson Parish Sheriff’s Office, et al.
E.D. La. · 2026 · confidence medium
Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986).
cited Cited as authority (rule) In re: Animo Services, LLC; Areya Holder Aurzada, Trustee v. Eastbanc Technologies, LLC
Bankr. N.D. Tex. · 2026 · confidence medium
Dist., 938 F.3d 724, 735 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) In re: Animo Services, LLC v. Unqork, Inc.
Bankr. N.D. Tex. · 2026 · confidence medium
Dist., 938 F.3d 724, 735 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) Revive RX, LLC v. Reed Hoelscher
N.D. Tex. · 2026 · confidence medium
Kane Enters. v. MacGregor (USA), Inc., 322 F.3d 371, 374 (5th Cir. 2003); Campbell v. Wells Fargo Bank, 781 F.2d 440, 442 (5th Cir. 1986).
discussed Cited as authority (rule) Ronald J. Sommers, Chapter 7 Trustee for Anadrill Directional Services Inc. v. Capybara Capital, LLC; Seamless Capital Group LLC
Bankr. S.D. Tex. · 2026 · confidence medium
Servs., Inc. v. Singh, 428 F.3d 559 , 570 (5th Cir. 2005). 73 Campbell v. Wells Fargo Bank, 781 F.2d 440, 442 (5th Cir. 1986). 74 Stokes v. Gann, 498 F. 3d 483, 484 (5th Cir. 2007) (per curiam). 75 Koppel v. 4987 Corp., 167 F.3d 125, 133 (2d Cir. 1999). 76 Hertz Corp. v. City of New York, 1 F.3d 121, 125 (2d Cir. 1993). 77 Southland Sec.
discussed Cited as authority (rule) In re: Anadrill Directional Services Inc.; Ronald J. Sommers v. Global Merchant Cash, Inc.
Bankr. S.D. Tex. · 2026 · confidence medium
Servs., Inc. v. Singh, 428 F.3d 559 , 570 (5th Cir. 2005). 35 Campbell v. Wells Fargo Bank, 781 F.2d 440, 442 (5th Cir. 1986). 36 Stokes v. Gann, 498 F. 3d 483, 484 (5th Cir. 2007) (per curiam). the legal feasibility of the complaint, not weigh the evidence that might be offered in its support.37 The Court’s consideration “is limited to facts stated on the face of the complaint and in the documents appended to the complaint or incorporated in the complaint by reference, as well as to matters of which judicial notice may be taken.”38 And although this Court “will not strain to find infe…
cited Cited as authority (rule) In re: Roofing Designs by JR, LLC v. Bonifacio Tapia dba MBTL Roofing Specialist, LLC.
Bankr. N.D. Tex. · 2026 · confidence medium
Dist., 938 F.3d 724, 735 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)). 9 Southland Sec.
cited Cited as authority (rule) Megan Hanson v. American Airlines, Inc.
N.D. Tex. · 2025 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
discussed Cited as authority (rule) Gregory Boyd; ET AL. v. Banco Popular de Puerto Rico
D.P.R. · 2025 · confidence medium
The BHCA “does not say that any actual loan in 15 The Seventh Circuit additionally noted in Mid-State Fertilizer Co. that the Fifth Circuit subsequently “trimmed Swedloff’s “sails” in Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 443 (5th Cir. 1986).
discussed Cited as authority (rule) In re: Deondra Joyce Kheir v. Titan Team LLC, The Money Source Inc., and Auction.com
Bankr. S.D. Tex. · 2025 · confidence medium
Servs., Inc. v. Singh, 428 F.3d 559 , 570 (5th Cir. 2005). 36 Campbell v. Wells Fargo Bank, 781 F.2d 440, 442 (5th Cir. 1986). 37 Stokes v. Gann, 498 F. 3d 483, 484 (5th Cir. 2007) (per curiam). 38 Koppel v. 4987 Corp., 167 F.3d 125, 133 (2d Cir. 1999). matters of which judicial notice may be taken.”39 And although this Court “will not strain to find inferences favorable to the plaintiff[],”40 the facts need only be sufficient “for an inference to be drawn that the elements of the claim exist.”41 To defeat a motion to dismiss pursuant to Rule 12(b)(6), a plaintiff must meet Rule 8(a)…
cited Cited as authority (rule) Laster v. Rankin County School District
S.D. Miss. · 2025 · confidence medium
Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986).
cited Cited as authority (rule) Seidel v. Hudson Clean Energy Enterprises, LLC
Bankr. N.D. Tex. · 2025 · confidence medium
Dist., 938 F.3d 724, 735 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) Ortiz v. Eagle Mountain Saginaw Independent School District
N.D. Tex. · 2025 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) Lynch v. Deutsche Bank National Trust Company
N.D. Tex. · 2025 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) Long v. Kerecis LLC
S.D. Miss. · 2025 · confidence medium
Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986).
cited Cited as authority (rule) Douglas v. Onin Staffing, LLC
S.D. Miss. · 2025 · confidence medium
Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986).
cited Cited as authority (rule) Zarate v. Coger
S.D. Tex. · 2025 · confidence medium
Campbell v. Wells Fargo Bank, 781 F.2d 440, 442 (5th Cir.1986).
cited Cited as authority (rule) Groves v. The City of Pearl, Mississippi
S.D. Miss. · 2025 · confidence medium
Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986). 2.
cited Cited as authority (rule) Barnum v. Blanson
S.D. Tex. · 2025 · confidence medium
Campbell v. Wells Fargo Bank, 781 F.2d 440, 442 (5th Cir.1986).
cited Cited as authority (rule) United States Securities and Exchange Commission v. McMillan
N.D. Tex. · 2025 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) Smith v. Linthicum
S.D. Tex. · 2025 · confidence medium
Wells Fargo Bank, 781 F.2d 440, 442 (5" Cir.1986).
cited Cited as authority (rule) Seidel v. MSouth Equity Partners III, L.P.
Bankr. N.D. Tex. · 2025 · confidence medium
Dist., 938 F.3d 724, 735 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)). 8 Southland Sec.
cited Cited as authority (rule) Taylor v. Lockheed Martin Aeronautics Company
N.D. Tex. · 2025 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) Hernandez v. Causey
5th Cir. · 2024 · confidence medium
Dist., 938 F.3d 724 , 735 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) Karahogitis v. TPUSA, Inc.
N.D. Tex. · 2024 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) Barnhizer v. American Airlines, Inc.
N.D. Tex. · 2024 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) Johnson v. Dallas County Hospital District
N.D. Tex. · 2024 · confidence medium
Dist., 938 F.3d 724 , 735 (5th Cir. 2019) (citing Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986).
cited Cited as authority (rule) MORRIS v. Kelly-Moore Paint Company Inc
N.D. Tex. · 2024 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) Dawes v. Likewize Corp.
N.D. Tex. · 2024 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) Mobolutions, LLC v. Geon Performance Solutions, LLC
E.D. Tex. · 2024 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th.
cited Cited as authority (rule) White v. Fifth Third Bank, National Association
E.D. Tex. · 2024 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th.
cited Cited as authority (rule) SJM Irrevocable Family Trust v. City of Runaway Bay, Texas
N.D. Tex. · 2024 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) Griffin v. Inogen
E.D. Tex. · 2024 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th.
cited Cited as authority (rule) McWilson v. Bell Textron Inc.
N.D. Tex. · 2024 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) Boysen v. Target Corporation
N.D. Tex. · 2024 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) Vetstem,Inc. v. Innovations Medspa, P.A.
N.D. Tex. · 2024 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) Jenkins v. Tahmahkera
N.D. Tex. · 2024 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) Simon v. Collier
S.D. Tex. · 2024 · confidence medium
Co., 563 F.3d 141, 147 (5th Cir. 2009) (citing Campbell v. Wells Fargo Bank, 781 F.2d 440, 442 (5th Cir. 1986)).
discussed Cited as authority (rule) Garcia Grain Trading Corp. v. Plascencia, Sr.
Bankr. S.D. Tex. · 2024 · confidence medium
Servs., Inc. v. Singh, 428 F.3d 559 , 570 (5th Cir. 2005). 29 Campbell v. Wells Fargo Bank, 781 F.2d 440, 442 (5th Cir. 1986). 30 Stokes v. Gann, 498 F. 3d 483, 484 (5th Cir. 2007) (per curiam). 31 Koppel v. 4987 Corp., 167 F.3d 125, 133 (2d Cir. 1999). 32 Hertz Corp. v. City of New York, 1 F.3d 121, 125 (2d Cir. 1993). 33 Southland Sec.
cited Cited as authority (rule) Haferbier v. IMER USA, Inc.
N.D. Tex. · 2024 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) Crum & Forster Specialty Insurance Company v. Smallwood
N.D. Tex. · 2024 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) Anthology, Inc. v. Tarrant County College District
N.D. Tex. · 2024 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
cited Cited as authority (rule) Beneficient v. Gladstone
E.D. Tex. · 2024 · confidence medium
State Univ., 714 F.3d 322, 330 (5th Cir. 2013); Campbell v. Wells Fargo Bank, M.A., 781 F.2d 440, 442 (5th Cir. 1986).
cited Cited as authority (rule) Hamby v. Wilson
E.D. Tex. · 2024 · confidence medium
Campbell v. Wells Fargo Bank, M.A., 781 F.2d 440, 442 (5th Cir. 1986).
cited Cited as authority (rule) Legacy Housing Corporation v. Rodwell
N.D. Tex. · 2024 · confidence medium
Co., 920 F.3d 890, 899 (5th Cir. 2019) (quoting Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986)).
Retrieving the full opinion text from the archive…
Rhett G. CAMPBELL, Trustee, Plaintiff-Appellant, Joseph C. Canizaro, Intervenor-Appellant,
v.
WELLS FARGO BANK, N.A., Et Al., Defendants-Appellees
85-4146.
Court of Appeals for the Fifth Circuit.
Jan 28, 1986.
781 F.2d 440
Morris & Campbell, Rhett G. Campbell, Edward T. Cotham, Jr., Houston, Tex., Robert H. Schmolke, Baton Rouge, La., Mark Cotham, Houston, Tex., William L. Goode, John D. Brasher, Jr., Lafayette, La., for appellants., Hargrove, Guyton, Ramey & Barlow, Glenn L. Langley, Shreveport, La., Murphy, Weir, & Burler, M. Kip Maly, San Francisco, Cal., Richard S. Odom, Jeffery D. Hermann, Los Angeles, Cal., R. Patrick Vance, New Orleans, La., for defendants-appellees.
Gee, Johnson, Fisher.
Cited by 231 opinions  |  Published
GEE, Circuit Judge:

Latham Exploration Company (“LEX-CO”) was organized under the laws of Louisiana in 1980 for conducting exploratory drilling operations. In 1982, LEXCO entered into a farm-out agreement with Chevron on certain Chevron leases in Pointe Coupee Parish, Louisiana. Under this arrangement, LEXCO was to drill five wells and earn certain leasehold rights. LEXCO then contracted with the plaintiffs to advance funds and equipment for the five wells in return for the assignment of a certain working interest in LEXCO’s leasehold rights.

Throughout this time, LEXCO was suffering severe cash-flow problems and was repeatedly forced to draw upon credit with the defendant banks. At last, LEXCO was overwhelmed by these financial pressures, filing for bankruptcy under Chapter 11 of the Federal Bankruptcy Code in the Western District of Louisiana.

Joseph Canizaro and Rhett G. Campbell brought this action in the district court against the multiple defendant banks (“Banks") seeking damages and other relief under the Bank Tying Act, 12 U.S.C. § 1971, et seq. The plaintiffs claimed that they were injured by the Banks’ intrusions into LEXCO’s operations. The Banks, it is alleged, imposed increasingly onerous conditions upon LEXCO for credit extensions, forcing LEXCO to curtail the Point Coupee operations. This cessation of activity at the well sites resulted in the plaintiffs’ interests being encumbered with liens imposed by Louisiana law for LEXCO’s creditors.

The district court granted the defendants’ motion, pursuant to Fed.R.Civ.P. 12(b)(6), to dismiss the plaintiffs’ Tying Act claims on the ground that since the plaintiffs had no direct relationship with the banks, contractual or otherwise, they lacked standing to sue under § 1975 of the Tying Act. The plaintiffs now appeal.

I. STANDING PER SE UNDER § 1975

12 U.S.C. § 1975 provides, in pertinent part, that: “Any person who is injured in his business or property by reason of anything forbidden in § 1972 of this title may sue therefor in any district court of the United States ...”

[*442] The plaintiffs argue vigorously that the district court erred in holding that non-customers of the bank have no standing per se under § 1975. Noting the use of the word “customer” in § 1972, [1] and the use of the broader term “person” in § 1975, the plaintiffs cite the general rule that “where Congress has carefully employed a term in one place but excluded it in another, it should be excluded.” J. Ray McDermott and Co., Inc. v. Vessel Morning Star, 457 F.2d 815, 818 (5th Cir.1972). This rule of exclusion, however, is only an aid to statutory construction, not a rule of law. The controlling consideration is legislative intent, and the maxim can be overcome by a strong indication of contrary congressional intent. United States Dept. of Justice v. F.L.R.B., 727 F.2d 481, 491 (5th Cir.1984).

The district court noted that only two reported decisions have addressed the issue of standing under the Act: Swerdloff v. Miami National Bank, 584 F.2d 54 (5th Cir.1978) and Costner v. Blount National Bank, 578 F.2d 1192 (6th Cir.1978). The parties agree that these cases both hold, in effect, that plaintiffs who deal directly with a bank possess standing to sue for violations of § 1972. Neither case, however, speaks to whether non-customers lack standing per se under § 1975.

Scouring the admittedly sparse legislative history of the Tying Act, we find no evidence that Congress intended for bank customers alone to have standing under § 1975. It may very well be that, under general principles of standing, most non-customer injuries will be too remote to furnish a basis for recovery under the act. That is, however, entirely different from a blanket holding that non-customers have no standing under § 1975 as a matter of law. We therefore conclude that the district court erred in holding that non-customers lack standing per se under § 1975.

II. STANDING UNDER THE COMMON LAW

Even though the district court erred in holding that the appellants lacked standing per se to pursue their Tying Act claims, we must still consider its apparent alternate basis for the dismissal: that the plaintiffs’ injuries were too remote under general principles of standing. The court observed that in the absence of any direct contractual relationship with the Banks, the plaintiffs’ injuries were “derived from the adversity suffered by LEXCO, and that the economic nexus between the Banks’ activity and the harm to plaintiffs is remote in comparison with the harm suffered by the consumer plaintiff in Blue Shield of Virginia v. McCready, 457 U.S. 465, 102 S.Ct. 2540, 73 L.Ed.2d 149 (1982).”

A 12(b)(6) motion to dismiss should not be granted unless it appears beyond doubt that the plaintiff can prove no set of facts in support of his claim which would entitle him to relief. The district court was, and we are, required to accept as true all well pleaded facts in the complaint; and the complaint is to be liberally construed in favor of the plaintiff. Abdul Alim Amin [*443] v. Universal Life Insurance Co. of Memphis, 706 F.2d 638, 640 (5th Cir.1983). It is not, however, necessary or proper to assume that the plaintiffs can prove facts that they have not alleged or that the defendants violated the Bank Tying Act in ways that have not been alleged. Assoc. General Contractors v. Cal. State Council of Carpenters, 459 U.S. 519, 526, 103 S.Ct. 897, 910, 74 L.Ed.2d 723 (1983).

The purpose and effect of § 1972 is to apply the general principles of the Sherman Antitrust Act to the field of commercial banking, without requiring plaintiffs to establish either the economic power of a bank or the specific anticompetitive effects of tying arrangements. Parsons Steel v. First Alabama Bank of Montgomery, 679 F.2d 242, 245 (11th Cir.1982). In construing the Tying Act, then, reference to antitrust statutes and decisions is “most pertinent in view of the substantial similarity of the Acts.” Swerdloff v. Miami National Bank, 584 F.2d 54, 58-59 (5th Cir.1978).

The class of persons entitled to maintain a private damage action under the antitrust laws is defined in § 4 of the Clayton Act, 15 U.S.C. § 15. It provides, in language all but identical to that before us today, that “Any person who shall be injured in his business or property by reason of anything forbidden in the antitrust laws may sue in any district court of the United States ...” (emphasis added).

The Supreme Court recently remarked that “A literal reading of [§ 4 of the Clayton Act] is broad enough to encompass every harm that can be attributed directly or indirectly to the consequences of an antitrust violation.” Associated General Contractors of California, supra, 459 U.S. at 529, 103 S.Ct. at 904. However, “an antitrust violation may be expected to cause ripples of harm through the nation’s economy, but ‘despite the broad wording of § 4, there is a point at which the wrongdoer should not be held liable.’ ” Id. 459 U.S. at 534, 103 S.Ct. at 907, quoting Illinois Brick Co. v. Illinois, 431 U.S. 420, at 760, 97 S.Ct. 2061 at 2082, 52 L.Ed.2d 707. Therefore, whether the plaintiffs “may recover for the injury [they] allegedly suffered by reason of the defendants’ coercion against third parties cannot be answered simply by reference to the broad language of § 4. Instead, as was required in common-law damages litigation in 1890, the question requires us to evaluate the plaintiffs’ harm, the alleged wrongdoing by the defendants, and the relationship between them.” Id. 459 U.S. at 535, 103 S.Ct. at 907.

Thus, in order to have standing to recover under § 4 of the Clayton Act, an antitrust plaintiff must demonstrate that his injury was a direct consequence of the alleged antitrust violation, that the extent of his injury is determinable and not speculative, and that recovery by him will not duplicate potential recovery by other plaintiffs. Walker v. U-Haul of Mississippi, 747 F.2d 1011, 1014 (5th Cir.1984).

Applying the foregoing antitrust principles to the claims at bar, we conclude that there is no need to decide whether the plaintiffs’ injuries are determinable and whether recovery for them would be dupli-cative, since the injuries claimed are not a direct consequence of the alleged activities of the defendants. The plaintiffs assert that the illegal tying activities of the defendants forced LEXCO into bankruptcy and that this, in turn, required LEXCO to cease its drilling operations. The cessation of drilling operations resulted in creditors of LEXCO imposing liens on the wells-liens which necessarily encumbered the working interests of the plaintiffs. In short, the plaintiffs were damaged by LEX-CO’s inability to meet its obligations. Even assuming that the plaintiffs’ allegations are true and the defendants’ illegal activities resulted in LEXCO’s demise, we hold that the plaintiffs’ injuries were not a direct consequence of the defendants’ activities. Accordingly, the district court’s dismissal is

AFFIRMED.

1

. § 1972 provides, in pertinent part:

(1) A bank shall not in any manner extend credit, lease, or sell property of any kind, or furnish any service, or fix or vary the consideration for any of the foregoing, on the condition or requirement:
(A) that the customer shall obtain some additional credit, property, or service from such bank other than a loan, discount, deposit, or trust service;
(B) that the customer shall obtain some additional credit, property, or service from a bank holding company of such bank, or from any other subsidiary of such bank holding company;
(C) that the customer provide some additional credit, property, or service to a bank holding company of such bank, other than those related to and usually provided in connection with a loan, discount, deposit, or trust service.
(D) that the customer provide some additional credit, property, or service to a bank holding company of such bank, or to any subsidiary of such bank holding company; or,
(E) that the customer shall not obtain some other credit, property, or service from a competitor of such bank, a bank holding company of such bank, or any subsidiary of such bank holding company, other than a condition or requirement that such bank shall reasonably impose in a credit transaction to assure the soundness of the credit.