Case Citator › Minn-Chem, Inc. v. Agrium Inc.

Minn-Chem, Inc. v. Agrium Inc.

Is it still good law? What later courts have actually done to this case.

Declined by some courts
Court
Seventh Circuit
Citation
683 F.3d 845
Decided
Confirmed treatments
1
Flagged citations read
124 of 124
Citing cases (total)
169
Treatment dates
2015
Declined by some courts
At least one reviewed court has declined to follow this case. No reviewed court has overruled it. The Ninth Circuit kept a stricter test for a direct domestic effect under the Foreign Trade Antitrust Improvements Act than Minn-Chem, Inc. v. Agrium Inc. adopted. That confirmed refusal to follow is listed below.
More on how this was screened

All 124 flagged citations have been read. Other opinions applied Minn-Chem or reported its overruling of United Phosphorus, Ltd. v. Angus Chemical Co.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

169 later cases cite Minn-Chem, Inc. v. Agrium Inc.; 124 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

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Treatments

Declined to follow

  • The Ninth Circuit retained its stricter definition of a “direct” domestic effect despite Minn-Chem's contrary interpretation, because a panel could not reconsider its own circuit precedent.

    United States v. Hui Hsiung · Ninth Circuit · filed

    Both the Second Circuit and the Seventh Circuit disagree with this definition of “direct.” See Lotes, 753 F.3d at 398 (choosing instead to [i]nterpret[]‘direct’ to require only a reasonably proximate causal nexus”); Minn-Chem, 683 F.3d at 857 (“Superimposing the idea of ‘immediate consequence’ on top of the full phrase results in a stricter test than the complete statute can bear.”). Whether our circuit should reconsider the stricter standard we impose is not within the province of this panel. Miller v. Gammie, 335 F.3d 889, 899 (9th Cir. 2003) (en banc) (“[A] three-judge panel may not overrule a prior decision of the court.”). But, in any event, the result is the same and the defendants benefit from our circuit’s formulation.
    Read the full opinion on CourtListener →

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