Díaz Aviation Corp. v. Airport Aviation Services, Inc.
716 F.3d 256
| 1st Cir. | 2013Background
- Diaz Aviation operated at LMMIA in Puerto Rico since 1960 and began selling aviation fuel by 1985.
- Plaintiff alleged a corrupt nexus between AAS and PRPA to drive Diaz Aviation out of business through improper actions around fueling operations.
- Defendants included AAS and its employees, and PRPA and multiple PRPA employees; district court dismissed some claims and later entered judgment for others after a bench trial.
- Key incidents include 2005 eviction action, 2009 PRPA actions removing Diaz permits and trucks, and 2010 PRPA move removing a military aircraft Diaz was fueling.
- The case proceeded to a bench trial focused on Sherman Act §1 and Article 1802 claims; Diaz represented himself despite advice to retain outside counsel.
- On appeal, Diaz challenged the judgment on several but not all interlocutory orders; the court narrowly limited review to the final judgments favoring certain defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Scope of appeal and notice requirements | Diaz Aviation intended to appeal final judgment and reconsideration denial. | PRPA defendants' prior dismissals not properly appealed due to notice issues. | Appeal deemed limited to denial of reconsideration; lacked sufficient notice to review earlier PRPA dismissals. |
| Whether the district court erred in granting non-suit under Rule 52(c) for AAS, Algarin, and Matos | Evidence supported conspiracy and anticompetitive conduct against defendants. | District court properly credited credibility and found no provable conspiracy or unreasonable conduct. | affirmed; district court's Rule 52(c) non-suit affirmed as not clearly erroneous. |
| Whether Diaz Aviation proved a Sherman Act §1 conspiracy between AAS and PRPA | Email chain showed coordination to restrain Diaz Aviation’s fuel business. | Emails showed security considerations, not a coercive conspiracy; actions were reasonable. | No reversible error; no concerted action proven and actions were procompetitive/security-minded. |
| Whether Diaz Aviation proved Sherman Act §1 unreasonable restraints under the rule of reason | Actions harmed Diaz Aviation and restrained competition. | No market definition or economic evidence of anticompetitive effect; actions justified by safety and security. | No liability under the rule of reason; no anticompetitive effect shown. |
| Whether Diaz Aviation stated a cognizable Article 1802 claim | Distrust in contract dealings and deliberate wrongful acts harmed Diaz Aviation. | AAS actions were contract-based and not negligent or wrongful; PRPA actions were not shown to be caused by AAS. | No Article 1802 liability; evidence failed to show wrongful acts or causation; damages unquantified. |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (plausibility pleading standard for §1 claims)
- Copperweld Corp. v. Independence Tube Corp., 467 U.S. 752 (U.S. 1984) (separation of intra-enterprise conduct from conspiracy)
- Gonzalez-Maldonado v. MMM Healthcare, Inc., 693 F.3d 244 (1st Cir. 2012) (interpretation of anti-competitive conduct in health care context)
- Leegin Creative Leather Prods., Inc. v. PSKS, Inc., 551 U.S. 877 (U.S. 2007) (rule of reason governs most restraints; per se not applicable here)
- United States v. Grinnell Corp., 384 U.S. 563 (U.S. 1966) (monopoly power elements and market power framework)
- Spectrum Sports, Inc. v. McQuillan, 506 U.S. 447 (U.S. 1993) (monopolization with intent and dangerous probability framework)
- Coastal Fuels of P.R., Inc. v. Caribbean Petroleum Corp., 79 F.3d 182 (1st Cir. 1996) (market definition and power considerations in antitrust context)