## Facts

- An individual retail consumer bought hearing aids for personal use.
- She alleged that hearing-aid manufacturers conspired to fix prices in violation of federal antitrust laws.
- She claimed the conspiracy forced consumers to pay higher prices for hearing aids and related services purchased from retail dealers.
- She filed a nationwide consumer class action seeking treble damages under § 4 of the Clayton Act for injury to “business or property.”
- The district court held that a retail purchaser is injured in “property” if antitrust violations increased the price paid, but certified the issue for interlocutory review.
- The Eighth Circuit reversed, holding that retail consumers alleging no commercial injury are not injured in “business or property” under § 4.
- The Supreme Court granted review to decide whether consumer overcharges for personal-use purchases qualify as injury to “business or property” under § 4.

## Issues

1. Whether a retail consumer who pays an allegedly antitrust-inflated price for personal-use goods suffers injury to “business or property” under § 4 of the Clayton Act.
2. Whether “business or property” limits § 4 treble-damages standing to persons engaged in commercial ventures.

## Decision

- The Supreme Court reversed the Eighth Circuit and remanded.
- Consumers who pay higher prices for personal-use goods due to antitrust violations suffer injury to “property” within § 4.
- The term “property” includes money; monetary loss alone can constitute a “property” injury.
- The disjunctive phrase “business or property” gives “property” an independent meaning and does not confine standing to business plaintiffs.
- Policy concerns about increased litigation were deemed matters for Congress rather than a basis for narrowing the statute.

## Legal Principles

- Statutory interpretation begins with the text; “property” has a broad, ordinary meaning that includes anything of material value owned or possessed, including money.
- Because § 4 authorizes suit for injury to “business or property,” a plaintiff need not allege a business-related injury if a property injury is alleged.
- Paying an unlawful overcharge is a compensable “property” injury under § 4, even when the purchase is for personal use.
- Legislative materials support reading § 4’s treble-damages remedy to include consumers as potential private enforcers of the antitrust laws.

## Conclusion

A retail consumer alleging that antitrust violations caused her to pay an inflated price for personal-use goods pleads injury to “property” under § 4 of the Clayton Act and therefore has standing to seek treble damages.


Reiter v. Sonotone Corp., 442 U.S. 330 (1979)