Reading Too Much into Reeder-Simco?

This Note argues that a careful analysis of the Supreme Court’s opinion in Volvo Trucks North America, Inc. v. Reeder-Simco GMC, Inc. demonstrates that, despite the expansive dicta appearing in part IV of that opinion, the Court did not intend to reshape the course of its Robinson-Patman Act jurisprudence in any significant way. The Court’s opinion operated well within the confines of established Robinson-Patman Act doctrine, even if its searching review of the evidence presented at trial represented a rare foray into the arena of factual error correction. After Reeder-Simco, however, many commentators emphasized the dicta in part IV of the opinion and argued that Reeder-Simco portended the end of a pillar of Robinson-Patman Act doctrine, the Morton Salt Inference. In light of the expansive interpretations that many commentators adopted after Reeder-Simco, this Note surveys citations to the opinion to determine whether such broad readings of the case have taken hold in the lower courts as well. The results show that courts have generally read the opinion narrowly and continue to apply the Morton Salt Inference in secondary-line Robinson-Patman Act cases.