## Facts

- Eastern Auto Distributors, Inc. (EAD) served as an independent wholesale distributor of Peugeot vehicles in a defined southeastern territory under a long-term distribution agreement with Peugeot Motors of America, Inc. (PMA), the exclusive U.S. importer and national distributor.
- PMA gradually absorbed other regional intermediaries, leaving EAD as the remaining independent intermediary distributor.
- EAD alleged PMA gave cash incentives, training, and related promotional support to retail dealers supplied directly by PMA but declined to provide comparable support to dealers supplied through EAD.
- EAD claimed the unequal payments and services constituted unlawful price discrimination and discriminatory promotional allowances under the Robinson-Patman Act.
- The evidence did not show that PMA-supplied dealers and EAD-supplied dealers competed for the same customers; reported cross-border sales were not shown to reflect dealer-to-dealer geographic competition.
- In the district court, antitrust claims (by both sides) and EAD’s civil conspiracy claim were dismissed on the pleadings; a directed verdict was entered for Automobiles Peugeot, S.A. (AP) on all claims and for PMA on EAD’s Robinson-Patman claims.
- The jury found for EAD on breach-of-contract claims for vehicle shortages ($50,000) and withdrawal of EAD’s Delaware territory ($262,042.23), found for PMA on EAD’s Automobile Dealers’ Day in Court Act claim, and rejected PMA’s contract counterclaim.

## Issues

1. Whether EAD’s evidence of promotional payments and services favoring PMA-supplied dealers was sufficient under the Robinson-Patman Act absent proof that favored and disfavored purchasers competed for the same customers.
2. Whether the jury’s breach-of-contract verdicts for EAD (vehicle shortages and withdrawal of Delaware territory) and the rejection of PMA’s contract counterclaim were supported by the evidence and free of reversible instructional or evidentiary error.
3. Whether the directed verdict for AP and the district court’s dismissal of federal antitrust and civil conspiracy claims were proper.

## Decision

- The Fourth Circuit affirmed the directed verdict for PMA on EAD’s Robinson-Patman claims.
- The court held EAD failed as a matter of law to show the required competitive relationship between the allegedly favored and disfavored dealers.
- The court affirmed the directed verdict for AP on all of EAD’s claims and affirmed dismissal of the antitrust and civil conspiracy counts.
- The court largely affirmed the contract-based judgment entered on the jury’s verdicts, including EAD’s contract damages awards and the rejection of PMA’s counterclaim.

## Legal Principles

- Robinson-Patman liability requires discrimination affecting purchasers who actually compete in resales to the same or overlapping customer base; differential treatment among noncompeting dealers does not satisfy the statute’s competitive-injury requirement.
- Sporadic cross-border sales, without proof they reflect dealer-to-dealer competition for customers, are insufficient to establish competition between favored and disfavored purchasers.
- Appellate review of jury contract verdicts is deferential; where the evidence permits a reasonable finding of breach and causation and instructions are not prejudicially erroneous, the verdict stands.
- Directed verdicts are appropriate when, even viewing evidence favorably to the nonmovant, no reasonable jury could find an essential element of the claim.

## Conclusion

The Fourth Circuit held that EAD’s Robinson-Patman theory failed because EAD did not prove that PMA-favored and EAD-disfavored dealers competed for the same customers, and it otherwise left intact the core trial outcome: EAD recovered contract damages for shortages and territory withdrawal, while PMA prevailed on the statutory dealer-protection claim and failed on its counterclaim.


E. Auto Distribs., Inc. v. Peugeot Motors of Am., Inc., 795 F.2d 329 (4th Cir. 1986)