Agerton v. Pilgrim's Pride Corporation, No. 12-40085, 2013 U.S. App. LEXIS 17921, rev'g., Adams v. Pilgrim's Pride, No. 2:09-CV-397-RSP, 2011 U.S. Dist. LEXIS 124163 (E.D. Tex. Sept. 30, 2011)

(defendant, chicken processing company, encountered financial problems and got approval from bankruptcy court to idle or sell various facilities; as result of plant closure or idling, defendant canceled or rejected over 150 contracts with contract chicken growers; terminated growers sued under Sec. 192(e) of Packers and Stockyards Act for impermissibly manipulating or controlling chicken prices; trial court ruled for growers and awarded over $25 million to growers; on appeal, court reversed on basis that Sec. 192(e) only prohibits price manipulations affecting market prices which are anti-competitive or injurious to competition and has an anti-competitive effect; defendant's unilateral attempt to raise prices by reducing supply of chicken not inherently anti-competitive; defendant had overextended itself in commodity chicken market and was driving chicken prices down at its own expense, and simply reversed its strategy; defendant's unilateral action had nothing to do with competition and was legitimate response of rational market participant to market changes).