Bulkferts Inc. v. Salatin Inc.
The plaintiff, Bulkferts, Inc., sued Salatin and Franco Ferri, Inc., alleging a conspiracy to restrain trade and monopolize the fertilizer market under Section 1 of the Sherman Act, and violations of the Racketeer Influenced and Corrupt Organizations Act (RICO). Defendants moved to dismiss the complaint or for summary judgment. The court, presided over by District Judge Robert L. Carter, denied summary judgment for the Sherman Act count (count one), finding factual questions regarding the independence of actors and the attempt to monopolize. However, counts two and three, alleging RICO violations, were dismissed because the plaintiff failed to show that defendants were engaged in a pattern of racketeering activity related to obtaining an interest in or operating an enterprise. The court also discussed the Noerr-Pennington doctrine but deferred its application due to factual questions of intent.