## Facts

- Chrysler Motors Corporation operated dealer “sales incentive” (bonus) programs tied to dealer-specific quotas for retail sales or purchases from Chrysler.
- J. Truett Payne Co., Inc., a Chrysler dealer in Birmingham, Alabama, alleged Chrysler assigned it higher quotas than competing dealers.
- Payne alleged the higher quotas reduced its ability to earn bonuses, causing it to pay more per vehicle than competitors.
- Payne claimed the dollar amount of the alleged price difference multiplied by its purchases was $81,248 and asserted a going-concern value loss when it went out of business (estimated between $50,000 and $170,000).
- Chrysler contended the programs were nondiscriminatory and caused no injury to Payne or competition.

## Issues

1. Whether proof of a § 2(a) Robinson-Patman price discrimination violation, without more, entitles a private plaintiff to “automatic damages” equal to the price differential times units purchased.
2. What showing of actual injury and what standard of proof of the amount of damages § 4 of the Clayton Act requires in a private treble-damages action premised on alleged Robinson-Patman price discrimination.

## Decision

- The Supreme Court rejected the “automatic damages” theory; proof of a § 2(a) violation does not itself establish damages under § 4.
- The Court held a private treble-damages plaintiff must make some showing of actual injury to business or property attributable to conduct the antitrust laws were designed to prevent.
- The Court reaffirmed that, once violation and fact of injury are established, the amount of damages may be proven by a just and reasonable estimate rather than exact calculation.
- The Court vacated the Fifth Circuit’s judgment and remanded, directing that the lower courts first determine whether a § 2(a) violation occurred and, if so, reassess the sufficiency of Payne’s evidence of injury and damages under the proper standards.

## Legal Principles

- Section 2(a) (Robinson-Patman) defines a substantive prohibition that can be violated upon a showing the discrimination may substantially lessen competition; it does not itself supply a damages remedy.
- Section 4 of the Clayton Act permits treble damages only for a person “injured in his business or property” by reason of an antitrust violation; illegality alone is insufficient.
- A private plaintiff is not entitled to “automatic damages” measured solely by the price differential multiplied by the number of purchases.
- A plaintiff must present evidence of the fact of injury (causal, antitrust-type harm); after that showing, the amount of damages may be established by reasonable estimation and inference.

## Conclusion

The Court held that private Robinson-Patman plaintiffs seeking treble damages must prove actual antitrust injury and causation under Clayton Act § 4, and cannot recover damages automatically based on the price differential; however, once injury is shown, damages need not be proven with mathematical precision.


J. Truett Payne Co. v. Chrysler Motors Corp., 451 U.S. 557 (1981)