First Circuit Rejects Martha’s Vineyard Gas Price Fixing Case

The First Circuit has upheld summary judgment in favor of four gas stations on Martha’s Vineyard that were accused of fixing prices.  The complaint alleged that the prices on the island were substantially higher than those in near by Cape Cod.  The court found that transportation costs could explain the price difference, and the gas retail market on Martha’s Vineyard was susceptible to consciously parallel behavior leading to higher prices despite the lack of a price fixing agreement.  Where the evidence fails to exclude the possibility of individual decision making, the antitrust laws are not violated.

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