Source: cases/15usc1/f3d-929-914-paramount-media-v-village-of-bellwood.case
Case source: https://www.neochart.com/catalog/cases/f3d/volume_929/0914_01/index.html
Illinois has thus immunized the Village from Paramount's antitrust claims.
Paramount doesn't offer proof of either anticompetitive effects or a conspiracy to restrain trade between Image Media and the Village.
To prevail under the rule of reason in a § 1 case, Paramount must establish "(1) a contract, combination or conspiracy; (2) a resultant unreasonable restraint of trade in a relevant market; and (3) an accompanying injury."
Paramount doesn't offer proof of either anticompetitive effects or a conspiracy to restrain trade between Image Media and the Village.
This allegation is insufficient to support a § 1 claim.
casedsl 1.2 # author: Flash1 (gemini-3.8-flash-high) # triaged-by: Fable (2026-11-10) case /f3d/929/0914-01 name Paramount Media Grp., Inc. v. Vill. of Bellwood cite 929 F.3d 914 (2019) court United States Court of Appeals for the Seventh Circuit date 2019-07-16 url catalog/cases/f3d/volume_929/0914_01/index.html source ir/caselaw/f3d_929.jsonl sha1=644a544fd9ef9d8cf6d400947641f366f7a5305b chars=17278 opinion op : majority by Sykes @0..17278 controlling party p1 : Paramount Media Group (billboard company, plaintiff) v. Village of Bellwood and Image Media Advertising (competitor that won the Village's lease) theory t1 : Count V: the Village's lease of village-owned land to Image Media, under the village-property exception to its billboard-permit ban, as a conspiracy in restraint of trade law 15usc1 role applied posture civil; billboard company sued village and competitor under §§ 1 and 2 (and the Constitution) over a municipal ban on new billboard permits and the lease of village-owned property to the competitor; district court entered summary judgment for defendants; CA7 affirmed result claimant-lost defense state-action-immunity : satisfied [law] party p1 theory t1 route _whole pattern home-rule municipality regulating billboards and leasing its own land; private lessee shares the municipality's immunity rule @11784..12025 [quoted] | Municipalities receive immunity from federal antitrust laws if they "demonstrate that their anticompetitive activities were authorized by the State pursuant to state policy to displace competition with regulation or monopoly public service." fact @2074..2208 [supports] | In 2009 the Village passed Ordinance 9-4, which mandated that "no new off-site advertising sign permit will be issued by the village." fact @2872..2961 [supports] | In October 2012 the Village accepted Image Media's offer without responding to Paramount. fact @2522..2639 [cuts-against] | As luck would have it, the Village owned property at 1156 Bellwood Avenue, across the street from the Sodhi property. held @12747..12821 | Illinois has thus immunized the Village from Paramount's antitrust claims. gloss Image Media is covered derivatively: a private party cannot be held liable for conspiring with a Parker-protected entity (City of Columbia v. Omni Outdoor Advertising). ? holding: the court states the immunity as a holding but expressly declines to decide Paramount's only challenge to it, the possible market-participant exception (the Village acting as lessor of its own land), because the claims fail on the merits anyway. The immunity is therefore not the unconditional ground of decision. ? polarity: the Village's ownership of the leased parcel is tagged cuts-against only because it is the basis of the market-participant argument the court left open. element agreement : not-satisfied [no-evidence] party p1 theory t1 route _whole pattern municipal lease to the higher lump-sum bidder; no proof of a conspiracy to restrain trade fact @559..656 [supports] | The Village accepted an offer from Image Media Advertising, Inc., one of Paramount's competitors. held @14135..14269 | Paramount doesn't offer proof of either anticompetitive effects or a conspiracy to restrain trade between Image Media and the Village. ? holding: a single sentence disposes of both the conspiracy element and anticompetitive effects (the same sentence is the `held` of the restraint.rule-of-reason block); the court does not explain why the lease contract itself is not the required agreement. element restraint.rule-of-reason : not-satisfied [no-evidence] party p1 theory t1 route anticompetitive-effect pattern losing bidder for a municipal billboard lease shows harm to itself, not to competition rule @13819..14041 | To prevail under the rule of reason in a § 1 case, Paramount must establish "(1) a contract, combination or conspiracy; (2) a resultant unreasonable restraint of trade in a relevant market; and (3) an accompanying injury." fact @2405..2496 [supports] | In March 2012 the Village amended the ban to exempt "village owned or controlled property." fact @14270..14357 [cuts-against] | It instead complains that the Village and Image Media's conduct harmed it individually. held @14135..14269 | Paramount doesn't offer proof of either anticompetitive effects or a conspiracy to restrain trade between Image Media and the Village. held @14358..14413 | This allegation is insufficient to support a § 1 claim. gloss The court relies on NYNEX Corp. v. Discon: a § 1 plaintiff must prove harm to the competitive process, not just to a single competitor. The relevant-market discussion that follows (municipal boundaries as the market) is addressed to the § 2 claim.