Supreme Auto Transport, LLC v. Arcelor Mittal USA, Inc.

Summary

The Seventh Circuit affirmed dismissal of an indirect-purchaser antitrust class action against steel producers, holding that the plaintiffs' amended complaint—which redefined "steel products" from mill output to end-use consumer goods like cars and appliances—was time-barred because it did not relate back to the original complaint under Rule 15(c), as the original complaint gave no fair notice of the vastly expanded claims. The court also held, in the alternative, that the amended complaint failed to plausibly plead proximate causation between the alleged price-fixing conspiracy and plaintiffs' injuries, even in states that have repealed the Illinois Brick direct-purchaser rule, because the injuries were too remote and speculative given the complex supply chains for finished consumer goods. Key topics: antitrust conspiracy, statute of limitations, relation back, proximate causation, indirect purchasers, Illinois Brick repealer states.

Holdings

1. The amended complaint does not relate back because the original complaint did not give fair notice of the new claims; the claims are therefore time-barred.
2. The amended complaint fails to plausibly plead proximate causation because the plaintiffs' alleged injuries are too remote from the defendants' conduct; the plaintiffs purchased steel only as a component of complex consumer products, making tracing impossible.

Questions Presented

1. Whether the amended complaint relates back to the original complaint under Rule 15(c).
2. Whether the claims are time-barred.
3. Whether the amended complaint states a plausible claim for proximate causation.

Disposition

affirmed