Active Disposal, Inc. v. City of Darien

Dist. Ct. did not err in dismissing plaintiffs-waste haulers' lawsuit alleging that defendants-municipalities' exclusive contracts for trash disposal violated federal antitrust law. Ct. found that state-action doctrine that permits municipalities to engage in conduct that would otherwise violate antitrust law applied where: (1) Illinois statute (65 ILCS 5/11-19-1(a)) empowers municipalities to make exclusive contracts relating to collection of garbage; and (2) instant anti-competitive effects arising out of instant statute were foreseeable by legislature.