PHILADELPHIA – A federal judge in Pennsylvania has ruled that the value of eggs must be calculated by the price egg farmers paid to purchase them domestically.
In a June 1 ruling, U.S. District Judge Gene E.K. Pratter of the U.S. District Court for the Eastern District of Pennsylvania denied a “motion for a direct verdict on the affirmative defense of the Capper-Volstead immunity” for the United States Egg Marketers (USEM).
The court said Congress passed the Capper-Volstead Act in 1922 to “remove the threat of antitrust restrictions on certain kinds of collective activity.” At issue in this case was how to calculate the value of eggs.
The opinion said Black’s Law Dictionary defines value as the “monetary worth or price of something; the amount of goods, services, or money that something commands in an exchange.”
U.S. District Judge Gene E.K. Pratter University of Pennsylvania Law School
“The court must look to the price of goods paid by USEM in the domestic purchase of the eggs from non-members, not the price paid by foreign buyers,” Pratter said in her decision.
She noted that antitrust law focuses on prices paid in domestic markets.
“It attempts to limit domestic price fixing, not international violations,” she said. “Even in this case, the plaintiffs allege, and must prove, harm in the relevant domestic market. It makes little sense, when assessing an antitrust statute, to look to foreign prices to determine value.”
According to the opinion, the defendants wanted the court to look at the export buyer’s purchase price and the plaintiffs wanted the court to consider USEM’s purchase price. Pratter found that the Capper-Volstead Act didn’t apply in this case because the court “must look at the relevant market,” which is domestic.
“The Capper-Volstead Act requires the court to look at the value of goods handled by the cooperative,” the opinion said. “The goods are handled by the cooperative once they are purchased, and they are purchased domestically.”