OR · 15usc1:x-ancillary-restraints
Distinguishes naked restraints (per se) from restraints reasonably ancillary to an efficiency-enhancing integration or cooperative venture (evaluated under the Rule of Reason), though Dagher holds core activity of a lawful integrated joint venture (setting the price of its own product) does not even implicate the ancillary-restraints inquiry.
Exact element source
in restraint of trade or commerceSource:
docroot/ir/usc/title15.jsonl#title15_sec1; Unicode character offsets [135:168] (end exclusive); SHA-256 9c248965c2c712de1e3f3d52a17be4c90dfdcac5d3f9fea0b7220b164e2c2973.All variants
| Variant | Description | Merits instance blocks | Distinct cases | Example cases (up to 3 per group) |
|---|---|---|---|---|
| ancillary-restraint/pricing-of-ventures-own-products | 0 Satisfied 0; not satisfied 0; excluded context 1 | 0 | No counted merits examples Excluded context examples: /us/547/0001-01 — Supreme Court of the United States · 2006 — applied/alternative | |
| doctrine-inapplicable/core-activity-of-venture | 1 Satisfied 0; not satisfied 1; excluded context 0 | 1 | /us/547/0001-01 — Supreme Court of the United States · 2006 — not |
How courts decided this element
| Case | Element | Holding and scope | Variant | Exact source quotations |
|---|---|---|---|---|
| /us/547/0001-01 — Supreme Court of the United States · 2006 | Ancillary restraints doctrine (restraint subordinate and collateral to a legitimate productive integration) | not Counted merits instance applied / merits basis: law Ancillary-restraints is a sub-test for choosing the mode of analysis, not an element in its own right (carried under the law file's x- id). "not-satisfied" = respondents' attempt to invoke the doctrine to invalidate the pricing fails because the doctrine does not reach the venture's core activity. | doctrine-inapplicable/core-activity-of-venture | That doctrine governs the validity of restrictions imposed by a legitimate business collaboration, such as a business association or joint venture, on nonventure activities.Source: docroot/ir/caselaw/us_547.jsonl#/us/547/0001-01; Unicode character offsets [7102:7275] (end exclusive); SHA-256 5084a5ea36bd7dae778624421ca275b1bb30e1f70daa750450037b732cb132a3.We agree with petitioners that the ancillary restraints doctrine has no application here, where the business practice being challenged involves the core activity of the joint venture itself — namely, the pricing of the very goods produced and sold by Equilon.Source: docroot/ir/caselaw/us_547.jsonl#/us/547/0001-01; Unicode character offsets [7703:7962] (end exclusive); SHA-256 5084a5ea36bd7dae778624421ca275b1bb30e1f70daa750450037b732cb132a3. |
| /us/547/0001-01 — Supreme Court of the United States · 2006 | Ancillary restraints doctrine (restraint subordinate and collateral to a legitimate productive integration) | not Excluded from merits counts applied / alternative basis: law "Even if we were to invoke the doctrine": the pricing policy would pass it as clearly ancillary to the sale of the venture's own products. Split from the main block as an alternative ground. | ancillary-restraint/pricing-of-ventures-own-products | And even if we were to invoke the doctrine in these cases, Equilon’s pricing policy is clearly ancillary to the sale of its own products.Source: docroot/ir/caselaw/us_547.jsonl#/us/547/0001-01; Unicode character offsets [7963:8100] (end exclusive); SHA-256 5084a5ea36bd7dae778624421ca275b1bb30e1f70daa750450037b732cb132a3. |
Court interpretations
interpretation
That doctrine governs the validity of restrictions imposed by a legitimate business collaboration, such as a business association or joint venture, on nonventure activities.
/us/547/0001-01 — Supreme Court of the United States · 2006
That doctrine governs the validity of restrictions imposed by a legitimate business collaboration, such as a business association or joint venture, on nonventure activities.Source:
docroot/ir/caselaw/us_547.jsonl#/us/547/0001-01; Unicode character offsets [7102:7275] (end exclusive); SHA-256 5084a5ea36bd7dae778624421ca275b1bb30e1f70daa750450037b732cb132a3.Distinguishes naked restraints (per se) from restraints reasonably ancillary to an efficiency-enhancing integration or cooperative venture (evaluated under the Rule of Reason), though Dagher holds core activity of a lawful integrated joint venture (setting the price of its own product) does not even implicate the ancillary-restraints inquiry.
interpretation
Naked restraints are unlikely to have any redeeming value and so are usually accorded per se treatment. But ancillary restraints that “may contribute to the success of a cooperative venture that promises greater productivity and output” (id. at 189) demand the more thorough analysis provided by the rule of reason.
/f-supp-2d/385/0740-01 — United States District Court for the Northern District of Illinois · 2005
Naked restraints are unlikely to have any redeeming value and so are usually accorded per se treatment. But ancillary restraints that “may contribute to the success of a cooperative venture that promises greater productivity and output” (id. at 189) demand the more thorough analysis provided by the rule of reason.Source:
docroot/ir/caselaw/f_supp_2d_385.jsonl#/f-supp-2d/385/0740-01; Unicode character offsets [16295:16610] (end exclusive); SHA-256 061c34d0b500376f04d011b5ab2e2f1ac60dba2bb321f15089be5be4b7c5e5d9.Distinguishes naked restraints (per se) from restraints reasonably ancillary to an efficiency-enhancing integration or cooperative venture (evaluated under the Rule of Reason), though Dagher holds core activity of a lawful integrated joint venture (setting the price of its own product) does not even implicate the ancillary-restraints inquiry.