City of Oakland, California v. Oakland Raiders, et al.

In Lexmark International, Inc. v. Static Control Components, Inc., 572 U.S. 118, 126 (2014), this Court considered a multifactor balancing test of prudential standing that the lower courts had been applying to deny a cause of action to injured plaintiffs under the Lanham Act. The lower courts had purported to draw this multifactor test from this Court’s decisions regarding statutory standing under the antitrust laws—particularly Associated General Contractors of California, Inc. v. California State Council of Carpenters (AGC), 459 U.S. 519 (1983). But in Lexmark, this Court unanimously held that the lower courts had misunderstood AGC, rejected the multifactor test that they were applying, and clarified that federal courts have no power to deny injured plaintiffs a cause of action merely because “‘prudence’ dictates.” 572 U.S. at 128. Instead, this Court made it very clear that— on a proper understanding of AGC—the only appropriate limits on statutory standing for a plaintiff with actual injury were (1) the zone-of-interests test and (2) the requirement that a plaintiff show proximate cause. In the near decade since Lexmark, however, the lower courts have continued applying the very same test this Court invalidated in the Lanham Act context to claims under the antitrust laws—refusing to acknowledge either the reading of AGC or the limits on judge-made prudential “standing” rules that Lexmark laid out. The question presented is: May a court deny a plaintiff with an antitrust injury proximately caused by a defendant’s antitrust violation a Clayton Act cause of action based on a multifactor, prudential balancing test of “antitrust standing”?