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''Standard Oil Co. v. United States'', 337 U.S. 293 (1949), more commonly referred to as the ''Standard Stations'' case (because that was the brand name of the company whose exclusive dealing contracts were held unlawful in the case. and also because there is a 1911 case with the same caption ''Standard Oil Co. v. United States''), is a 1947 decision of the United States Supreme Court in which requirements contracts for gasoline stations (Standard Stations) were held to violate section 3 of the Clayton Act.〔15 U.S.C. § 14.〕 That statute prohibits selling goods on the condition that the customer must not deal in the goods of a competitor of the seller, such as in a requirements contract, if the effect is to "substantially lessen competition" or "tend to create a monopoly." The doctrine of this case has been referred to as "quantitative substantiality," and its exact contours were unsettled and controversial for many years〔See, e.g, Milton Handler, (''Quantitative Substantiality and the Celler-Kefauver Act—A Look at the Record'' ), 7 279, 288 (1956) ("()n ''Standard Stations'' 6.7% of the market for gasoline, 5% of lubricating oil and 2% of tires and batteries were all deemed substantial. If these decisions are reliable guides, then both horizontal and vertical integrations involving relatively small shares of the market would be vulnerable if quantitative substantiality were the prevailing doctrine. ...Do we want to strait-jacket the American economy by prohibiting integration, both vertical and horizontal, of this slight dimension?"); Stanley N. Barnes (''Highlights of Clayton Act Developments and Current Status—Quantitative Substantiality'' ), 8 , Washington, D.C., Apr. 5-6, 1956, at 21 (1956) (criticizing Handler analysis and concluding "the 'quantitative substantiality' debate adds more heat than light"); 141 (1955) ("a perplexing opinion whose rationale is not clear"); Earl W. Kintner, (''Exclusive Dealing'' ), Remarks Before N.Y.C. Bar Assn., Apr. 11, 1956, p. 5 ("To me, ''Standard Stations'' and ''Motion Picture Advertising Service'', read together, frame Section 3's competitive injury test in realistic terms of substantial market foreclosure."). 〕 until the Supreme Court authoritatively explained it in ''United States v. Philadelphia National Bank'' (''Philadelphia Bank'' case), 374 U.S. 321 (1963). The importance of the decision and its place in antitrust jurisprudence have been characterized in these terms: ''Standard Stations'' is the richest and the most difficult of all the vertical integration cases. Each of the tensions that has been mentioned within the structure of antitrust is revealed in the ''Standard Stations'' decision. As the leading case on integration by contract, it has been the subject of extensive commentary and controversy. The decision may raise as many problems as it settles, but the rule of ''Standard Stations'' is one which must be reckoned with in all vertical integration cases, and comprehension of this rule is essential to evaluation of the impact of antitrust upon integration.〔Friedrich Kessler and Richard H. Stern, (''Competition, Contract, and Vertical Integration'' ), 69 L.J. 1, 24 (1959).〕 The case has been the subject of extensive scholarly commentary.〔See, e.g., Louis B. Schwartz, (''Potential Impairment of Competition—The Impact of Standard Oil Co. of California v. United States on the Standard of Legality Under the Clayton Act'' ), 98 U. 10 (1949); William B. Lockhart & Howard R. Sacks, (''The Relevance of Economic Factors in Determining Whether Exclusive Arrangements Violate Section 3 of the Clayton Act'' ), 65 913 (1952); Richard McLaren, (''Related Problems of "Requirements" Contracts and Acquisitions in Vertical Integration Under the Anti-Trust Laws'' ), 45 141 (1950).〕 ==Background== Defendant Standard Stations, Inc., a wholly owned subsidiary of defendant Standard Oil Company of California (Socal) (now named Chevron Corporation), managed gasoline filling stations that Socal owned and leased to independent businessmen. It also supplied gasoline to locally owned and operated filling stations that used the Standard Stations brand name〔''Standard Stations'', 337 U.S. at 295 and n.1. See also ''id'' at 319 (dissenting opinion of Justice Douglas).〕 The ''Standard Stations'' case involved the distribution of petroleum products and automobile accessories. The US oil industry had relatively few producers, each having substantial shares of the market. They were integrated with their retail outlets by requirements contracts. These contracts bound the retail outlets to obtain all of the products they sold from the integrating producer.〔Kessler, 69 at 25 (citing ''Standard Stations'', 337 U.S. at 295).〕 Defendant Standard's contracts covered 16 percent of all the retail gasoline outlets in the Western US,〔The Western US was defined as Arizona, California, Idaho, Nevada, Oregon, Utah and Washington. ''Standard Stations'', 337 U.S. at 295.〕 6.7 percent of the gasoline sold in the Western US, and about $58 million in annual sales.〔Kessler, 69 at 25 (citing ''Standard Stations'', 337 U.S. at 295).〕 Standard's sales through outlets that its parent owned and to industrial users brought its total share of the Western US gasoline market up to 23 percent, while its six leading competitors, who employed similar exclusive dealing arrangements, accounted for 42 percent of that market. Together, the seven major companies sold 65 percent of gasoline in the Western US. Industrial gasoline sales of the seven majors brought the total above 65 percent.〔Kessler, 69 at 25 n.97.〕 In terms of retail outlets, the seven majors controlled 76 percent of all stations in the West.〔Kessler, 69 at 25.〕 The US Justice Department's Antitrust Division brought suit under section 1 of the Sherman Act〔15 U.S.C. § 1.〕 and section 3 of the Clayton Act〔15 U.S.C. § 14.〕 to enjoin Standard from entering into or enforcing these exclusive contracts. The district court found for the Government as to both sections 1 and 3.〔''United States v. Standard Oil Co.'', 78 F. Supp. 850 (S.D. Calif. 1948).〕 The defendants then appealed to the Supreme Court. 抄文引用元・出典: フリー百科事典『 ウィキペディア（Wikipedia）』 ■ウィキペディアで「Standard Oil Co. v. United States (Standard Stations)」の詳細全文を読む スポンサード リンク
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