475 U.S. 574 (U.S. 1986)
Matsushita Electric Industrial Co. v.
Whether antitrust plaintiffs opposing summary judgment on a §1 Sherman Act conspiracy claim based on alleged predatory pricing presented sufficient evidence—beyond conduct equally consistent with independent decisionmaking—to create a genuine issue of material fact, particularly where the alleged conspiracy is economically implausible.
Under Rule 56, the nonmoving party must set forth specific facts showing a genuine issue for trial; conclusory allegations or ambiguous evidence do not suffice. In §1 conspiracy cases, a plaintiff must present evidence that tends to exclude the possibility that the alleged conspirators acted independently (Monsanto Co. v. Spray-Rite). Conduct that is as consistent with permissible competition as with unlawful agreement does not, without more, support an inference of conspiracy. Courts may consider the economic plausibility of the alleged scheme; where the theory "makes no economic sense," more persuasive evidence is required before permitting a case to go to the jury. Antitrust law protects aggressive price competition; low prices are not themselves evidence of illegal collusion absent proof of agreement and a plausible mechanism for recoupment.
The Supreme Court reversed the Third Circuit and held that summary judgment for defendants was appropriate. Plaintiffs failed to offer evidence that tended to exclude independent action or to make plausible the alleged decades-long predatory pricing conspiracy.
Matsushita is a bedrock case for two propositions: (1) in §1 conspiracy claims, plaintiffs must present evidence tending to exclude independent conduct; and (2) courts may weigh the economic plausibility of the alleged conspiracy in deciding summary judgment. It powerfully cabins the use of ambiguous circumstantial evidence to infer collusion and reflects judicial skepticism toward predatory pricing conspiracies absent a plausible recoupment story. Doctrinally, it sits alongside Celotex and Anderson as a pillar of modern summary judgment jurisprudence. Substantively, it anticipates Brooke Group's later formalization of predatory pricing requirements. For law students, the case is essential for understanding how antitrust economics intersects with evidentiary burdens and how Rule 56 functions as a gatekeeping tool in complex antitrust litigation.