1st Circ. Clarifies Pleading Standard For Conspiracy Claims

Law360, New York (June 20, 2013, 9:24 PM EDT) -- The First Circuit on Wednesday held that plaintiffs in refusal-to-deal cases must only allege the basic contours of a plausible conspiracy to survive the pleading stage, rejecting a higher standard used to dismiss a recycling company's allegations that Solo Cup Co. and others colluded to boycott its services.

A three-judge panel of the First Circuit said that the U.S. District Court for the District of Massachusetts improperly applied a summary-judgment or post-trial standard when evaluating a motion to dismiss Evergreen Partnering Group's antitrust case.

The trial...
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