A group of cow-calf ranchers indirectly sold their cattle to the defendants, the four largest meat packing companies in the country. The ranchers raised and sold weaned calves to feedlots and stockers. Once the animals reached market weight, the feedlots would then sell the cattle to the meat packing companies under forward contracts or through the cash market. The ranchers brought this lawsuit alleging that the defendants conspired to suppress the price of fed cattle which “led to a parallel collapse of prices of cows and calves.” The plaintiffs claimed this violated the Sherman Act and the Packers and Stockyards Act.

Defendants argued that the plaintiffs did not adequately plead antitrust standing and moved to dismiss the lawsuit. To prove antitrust standing, the plaintiff must show, among other factors, a causal connection between the alleged antitrust violation and the plaintiff’s injury. Midwest Commc'ns v. Minn. Twins, Inc., 779 F.2d 444, 450 n.6 (8th Cir. 1985). The district court found that the plaintiffs failed to show how the defendants’ alleged actions caused a collapse in the fed cattle market and resulted in a downturn in the cow-calf market.

The plaintiffs did not show that they were the direct target of an anticompetitive activity or that their injury is traceable to defendants’ actions. Many years pass and multiple players are involved between the ranchers selling their livestock and the defendants purchasing the animals. Thus, the district court granted the defendants’ motion to dismiss.

In re: Cattle and Beef Antitrust Litigation, 2023 WL 5310905 (D. Minn. Aug. 17, 2023).