Ohio-Sealy Mattress Manufacturing Co. v. Sealy, Inc.

Summary

The Seventh Circuit affirmed a district court judgment in an antitrust action involving an alleged market-allocation scheme by Sealy, Inc. The court held that Ohio-Sealy could not reinstate the remitted portion of its jury award or recover supplemental damages in the same action. It also upheld the equitable decree, including the refusal to order divestiture or enjoin enforcement of the exclusive manufacturing territory clause, and dismissed Sealy’s contingent cross-appeal.

Holdings

1. The district court correctly refused to reinstate the remitted portion of the jury verdict because the prior appellate mandate affirmed the remitted judgment and foreclosed Ohio from seeking reinstatement.
2. Ohio could not recover supplemental damages in this action; any valid claim for damages that accrued after trial or was not provable at trial had to be pursued in a separate lawsuit.
3. The district court did not err by denying an evidentiary hearing because Ohio was not entitled to recover supplemental damages in this action as a matter of law.
4. A private antitrust equitable decree should extend only as far as necessary to protect the plaintiff from likely future harm and to prevent continuation of the specific unlawful practice; the district court's injunction adequately restored intrabrand competition.
5. The district court did not err by refusing to order divestiture of the three licensees or by declining to enjoin Sealy's exclusive manufacturing territory clause.

Questions Presented

1. Whether the district court could reinstate the portion of the jury verdict that had been remitted after Ohio accepted the remittitur.
2. Whether Ohio could recover supplemental damages in the same action for pre-verdict or post-verdict antitrust conduct.
3. Whether the district court erred by failing to hold an evidentiary hearing concerning supplemental damages.
4. Whether the equitable decree adequately protected Ohio from future harm and restored competition.
5. Whether the district court was required to order divestiture of Sealy licensees or enjoin enforcement of the exclusive manufacturing territory clause.

Disposition

affirmed