Parker doctrine (Connecticut) · Go Syfert
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Parker doctrine in Connecticut

5 Connecticut opinions name it 2 courts 1975–2008 0 in the last five years

The cases below were cited by Connecticut courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (4)

CaseFollowedCited
City of New Haven v. Bonnergreen
conn · 2005 · cited in 1 Connecticut opinions naming this issue, 2005–2005
2 sentences

2005See, e.g., New Haven v. Bonner, 272 Conn. 489, 497 , 863 A.2d 680 (2005) (declining to consider alternate ground for affirmance that was not raised before trial court). [17] The Sherman Act provides in relevant part: "Every contract, combination in the form of trust or otherwise, or conspiracy, in restraint of trade or commerce among the several States, or with foreign nations, is declared to be illegal. . . ." 15 U.S.C. § 1 . [18] Indeed, we note that the defendants cite multiple cases wherein municipal water and sewer companies have been held immune from federal antitrust liability under the

2005See, e.g., New Haven v. Bonner, 272 Conn. 489, 497 , 863 A.2d 680 (2005) (declining to consider alternate ground for affirmance that was not raised before trial court). [17] The Sherman Act provides in relevant part: "Every contract, combination in the form of trust or otherwise, or conspiracy, in restraint of trade or commerce among the several States, or with foreign nations, is declared to be illegal. . . ." 15 U.S.C. § 1 . [18] Indeed, we note that the defendants cite multiple cases wherein municipal water and sewer companies have been held immune from federal antitrust liability under the

11
Town of Hallie v. City of Eau Clairegreen
scotus · 1985 · cited in 1 Connecticut opinions naming this issue, 2005–2005
2 sentences

2005See, e.g., Hallie v. Eau Claire, supra, 471 U.S. at 42 , 105 S.Ct. 1713 (Stating that "it is sufficient that the statutes authorized the [c]ity to provide sewage services and also to determine the areas to be served.

2005See, e.g., Hallie v. Eau Claire, supra, 471 U.S. at 42 , 105 S.Ct. 1713 (Stating that "it is sufficient that the statutes authorized the [c]ity to provide sewage services and also to determine the areas to be served.

11
Fine Airport Parking, Inc. v. City of Tulsagreen
okla · 2003 · cited in 1 Connecticut opinions naming this issue, 2005–2005
2 sentences

2005See Fine Airport Parking, Inc. v. Tulsa, 71 P.3d 5, 10-11 (Okla. 2003) (acknowledging statute requiring state antitrust law to “be interpreted and applied consistent with federal antitrust law,” but stating that “[t]he principles of federalism supporting the Parker doctrine are meaningless in an analysis of municipal liability under [state antitrust statutes]” because “the state is the sovereign and the municipality is a political subdivision of the state”).

2005See Fine Airport Parking, Inc. v. Tulsa, 71 P.3d 5, 10-11 (Okla. 2003) (acknowledging statute requiring state antitrust law to “be interpreted and applied consistent with federal antitrust law,” but stating that “[t]he principles of federalism supporting the Parker doctrine are meaningless in an analysis of municipal liability under [state antitrust statutes]” because “the state is the sovereign and the municipality is a political subdivision of the state”).

11
Parker v. Browngreen
scotus · 1943 · cited in 1 Connecticut opinions naming this issue, 1991–1991
1 sentence

1991See Parker v. Brown, 317 U.S. 341 (1948), (which held that principles of federalism and state sovereignty render the Sherman Act inapplicable to anti-competitive restraints imposed by the state); and Hallie v. Eau Claire, 471 U.S. 361 (1985) (according Parker immunity to municipal restriction of competition in implementation of state policy).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Connecticut. Read the followed side critically anyway.

Also cited on this issue (13)

CaseCitedYears
City of Columbia v. Omni Outdoor Advertising, Inc. green
scotus · 1991
2 sentences

2008Ed. 315 (1943)].” (Internal quotation marks omitted.) Miller's Pond Co., LLC v. New London, supra, 273 Conn. 804 . “[I]n order to be shielded by qualified state action immunity, the defendant must show that its anti-competitive conduct was specifically directed or required by the government . . . .” (Internal quotation marks omitted.) Id., 806-807 . 15 In Parker v. Brown, supra, 317 U.S. 351 , the Supreme Court concluded that the Sherman Act was not “intended to restrain state action or official action directed by a state.” We noted in MiUer’s Pond Co., LLC, that, with respect to municipalitie

2008Ed. 315 (1943)].” (Internal quotation marks omitted.) Miller's Pond Co., LLC v. New London, supra, 273 Conn. 804 . “[I]n order to be shielded by qualified state action immunity, the defendant must show that its anti-competitive conduct was specifically directed or required by the government . . . .” (Internal quotation marks omitted.) Id., 806-807 . 15 In Parker v. Brown, supra, 317 U.S. 351 , the Supreme Court concluded that the Sherman Act was not “intended to restrain state action or official action directed by a state.” We noted in MiUer’s Pond Co., LLC, that, with respect to municipalitie

22005–2008
State v. Parker green
conn · 1984
1 sentence

2006Thus, as we observed in State v. Parker, supra, 194 Conn. 650 , even if the trial court improperly had denied Parker’s motion to dismiss the criminal charges against him on the basis of his successful completion of the terms of his accelerated rehabilitation, *232 Parker’s right to a dismissal of the charges was “fully capable of being vindicated after trial.” Id., 658 .

12006–2006
City of San Antonio, Texas v. Encore Videos, Inc green
scotus · 2003
2 sentences

2005Islandia v. Electrical Inspectors, Inc., 540 U.S. 982 , 124 S. Ct. 467 , 157 L.

2005Islandia v. Electrical Inspectors, Inc., 540 U.S. 982 , 124 S.Ct. 467 , 157 L.Ed.2d 373 (2003), quoting Columbia v. Omni Outdoor Advertising, Inc., supra, at 372, 111 S.Ct. 1344 .

12005–2005
Fotta v. Trustees of the United Mine Workers of America green
scotus · 2003
2 sentences

2005Islandia v. Electrical Inspectors, Inc., 540 U.S. 982 , 124 S. Ct. 467 , 157 L.

2005Islandia v. Electrical Inspectors, Inc., 540 U.S. 982 , 124 S.Ct. 467 , 157 L.Ed.2d 373 (2003), quoting Columbia v. Omni Outdoor Advertising, Inc., supra, at 372, 111 S.Ct. 1344 .

12005–2005
Wood v. Green, Clerk, Circuit Court of Florida, Lee County green
scotus · 2003
2 sentences

2005Islandia v. Electrical Inspectors, Inc., 540 U.S. 982 , 124 S. Ct. 467 , 157 L.

2005Islandia v. Electrical Inspectors, Inc., 540 U.S. 982 , 124 S.Ct. 467 , 157 L.Ed.2d 373 (2003), quoting Columbia v. Omni Outdoor Advertising, Inc., supra, at 372, 111 S.Ct. 1344 .

12005–2005
Professional Ambulance Service, Inc. v. Blackstone green
connsuperct · 1978
2 sentences

2005In Professional Ambulance Service, Inc. v. Blackstone, 35 Conn. Sup. 136, 137 , 400 A.2d 1031 (1978), the plaintiff was a private ambulance company who, along with two other private ambulance companies, previously had been dispatched by the East Hartford police department on a rotating basis to provide emergency medical services to the town.

2005In Professional Ambulance Service, Inc. v. Blackstone, 35 Conn. Sup. 136, 137 , 400 A.2d 1031 (1978), the plaintiff was a private ambulance company who, along with two other private ambulance companies, previously had been dispatched by the East Hartford police department on a rotating basis to provide emergency medical services to the town.

12005–2005
Mazzola v. Southern New England Telephone Co. green
conn · 1975
2 sentences

2005After reviewing the facts of Parker , this court stated that the " Parker doctrine draws a firm line, in short, between activities actually commanded by the state, which are immune from antitrust liability and action merely approved or tolerated." Id., at 361 , 363 A.2d 170 .

2005Nor can such activities consequently be comprehended within the more stringent standards applicable to exemptions from antitrust liability established by [§ 35-31(b)]. " (Citation omitted; emphasis added.) Id., at 365-66, 363 A.2d 170 .

12005–2005
Electrical Inspectors, Inc. v. Village Of East Hills green
ca2 · 2003
2 sentences

2005A municipality that desires Parker immunity must show that, under the state statutory scheme, it has both “ ‘authority to regulate’ ” and “ ‘authority to suppress competition.’ ” Electrical Inspectors, Inc. v. East Hills, 320 F.3d 110 , 118 (2d Cir. 2002), cert. denied sub nom.

2005A municipality that desires Parker immunity must show that, under the state statutory scheme, it has both "`authority to regulate'" and "`authority to suppress competition.'" Electrical Inspectors, Inc. v. East Hills, 320 F.3d 110 , 118 (2d Cir. 2002), cert. denied sub nom.

12005–2005
Goldfarb v. Virginia State Bar green
scotus · 1975
2 sentences

1975Goldfarb v. Virginia State Bar, 421 U.S. 773, 791 , 95 S. Ct. 2004 , 44 L.

1975Goldfarb v. Virginia State Bar, 421 U.S. 773, 791 , 95 S. Ct. 2004 , 44 L.

11975–1975
Gas Light Company of Columbus v. Georgia Power Company and the Southern Company green
ca5 · 1971
2 sentences

1975The theory underlying Washington Gas Light, also followed in Gas Light Co. of Columbus v. Georgia Power Co., 440 F.2d 1135 (5th Cir.), cert. denied, 404 U.S. 1062 , 92 S. Ct. 732 , 30 L.

1975The theory underlying Washington Gas Light, also followed in Gas Light Co. of Columbus v. Georgia Power Co., 440 F.2d 1135 (5th Cir.), cert. denied, 404 U.S. 1062 , 92 S. Ct. 732 , 30 L.

11975–1975
Business Aides, Inc., a Virginia Corporation v. The Chesapeake and Potomac Telephone Company of Virginia, a Virginia Corporation neutral
ca4 · 1973
2 sentences

1975Va.), aff'd, 480 F.2d 754 (4th Cir.). [17] 2 Under this analysis, the process provided in General Statutes § 16-19 whereby the PUC approves and thereby renders effective tariffs such as that proposed by the defendant in this case clearly does not amount to the kind of "state action" which invites application of the Parker doctrine.

1975Va.), aff'd, 480 F.2d 754 (4th Cir.). [17] 2 Under this analysis, the process provided in General Statutes § 16-19 whereby the PUC approves and thereby renders effective tariffs such as that proposed by the defendant in this case clearly does not amount to the kind of "state action" which invites application of the Parker doctrine.

11975–1975
Swenson v. Stidham green
scotus · 1972
2 sentences

1975The theory underlying Washington Gas Light, also followed in Gas Light Co. of Columbus v. Georgia Power Co., 440 F.2d 1135 (5th Cir.), cert. denied, 404 U.S. 1062 , 92 S. Ct. 732 , 30 L.

1975The theory underlying Washington Gas Light, also followed in Gas Light Co. of Columbus v. Georgia Power Co., 440 F.2d 1135 (5th Cir.), cert. denied, 404 U.S. 1062 , 92 S. Ct. 732 , 30 L.

11975–1975
Kennon v. United States green
scotus · 1972
2 sentences

1975The theory underlying Washington Gas Light, also followed in Gas Light Co. of Columbus v. Georgia Power Co., 440 F.2d 1135 (5th Cir.), cert. denied, 404 U.S. 1062 , 92 S. Ct. 732 , 30 L.

1975The theory underlying Washington Gas Light, also followed in Gas Light Co. of Columbus v. Georgia Power Co., 440 F.2d 1135 (5th Cir.), cert. denied, 404 U.S. 1062 , 92 S. Ct. 732 , 30 L.

11975–1975

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 35-24 (3) CT § Conn. Gen. Stat. § 35-31 (3) CT § Conn. Gen. Stat. § 35-35 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NY 82 (1977–2026) TX 28 (2000–2026) CA 19 (1961–2026) FL 18 (1985–2025) GA 14 (1989–2020) LA 13 (1977–2012) NC 10 (1969–2023) MI 9 (1981–2023) OH 9 (1986–2025) PA 8 (1957–2022) MO 7 (1964–2017) TN 6 (1995–2021) IL 6 (1983–2026) IN 6 (1989–2018) MS 6 (1998–2019) UT 6 (1995–2000) CO 5 (1975–2009) NJ 5 (1972–2021) KY 5 (1953–2018) WA 5 (1996–2024) AL 5 (1993–2017) CT 5 (1975–2008) AZ 5 (1973–2020) MN 4 (1984–2017) SC 4 (1955–2011) OK 4 (1992–2021) MA 3 (2007–2012) MD 3 (1977–2009) WI 3 (1998–2020) IA 2 (2012–2014) AR 2 (1959–2006) VT 2 (2007–2020) NM 2 (2015–2017) MT 2 (2005–2009) ID 2 (2015–2017) DC 2 (2017–2025)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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