In United National Maintenance Inc. v. San Diego Convention Center Corp. Inc., Southern District of California Judge dismissed a suit accusing San Diego Convention Center (SDC) of monopolizing cleaning services during trade shows and interfering with a janitorial vendor’s contract. The dispute began after the SDC enacted a policy requiring all cleaning services at trade shows to be performed only by the center’s in-house janitorial staff. In granting SDC’s motion for judgment as a matter of law, the court held that SDC is a state actor with a “broad grant of authority” from the legislature to supervise and manage the convention center; therefore it’s immune from the plaintiff’s antitrust claims. The court also held that the antitrust claims must be dismissed because SDC did not control a dominant share of the trade show cleaning services market in San Diego, and the SDC’s policy to use in-house staff did not have any obvious negative effect on consumers, prices or quality of services.