United States v. National City Lines, Inc.

Background

The United States sued nine corporations, including several bus companies and major suppliers, alleging a nationwide conspiracy to acquire local transit companies and to restrain or monopolize interstate commerce in motorbuses, petroleum supplies, tires, and tubes. The Government sought injunctive relief and divestiture. The companies moved to dismiss the civil complaint in the Southern District of California as an inconvenient forum and said Chicago would be more convenient. The district court accepted the defendants' affidavits and dismissed the case without prejudice to refiling in a more convenient forum.

Reasoning

The Court addressed whether Section 12 of the Clayton Act, which lets plaintiffs bring antitrust suits in districts where a corporation "transacts business," can be qualified by the nonstatutory forum non conveniens doctrine. The majority, relying on the statute's history and prior decisions, held Congress enlarged venue to help plaintiffs and the Government and did not leave courts discretion to defeat that choice. The Court emphasized Congress' intent to avoid forcing plaintiffs into distant forums, and warned that allowing forum non conveniens in multistate antitrust cases would create delay and a "merry-go-round" of litigation. The Supreme Court reversed the district court, so the Government prevailed on venue.

Real world impact

Practically, the ruling preserves the Government's and other plaintiffs' statutory right to choose among authorized districts in antitrust cases, making it harder for defendants to obtain dismissal on convenience grounds. It aims to limit extra delay from repeated forum fights in complex, nationwide suits. This decision is procedural and does not resolve the merits of the antitrust claims.

Dissents or concurrances

Justice Jackson concurred, agreeing the statutory scheme provides protections that make forum non conveniens unnecessary. Justice Frankfurter dissented, arguing courts should have discretion in the interest of justice and pointing to a companion criminal transfer under Rule 21(b) as relevant.