Carlin v. DairyAmerica, Inc.

At issue in this appeal were two issues: (1) whether the judicially created "filed rate doctrine," which typically has been utilized in common carrier and public utility litigation, was applicable in a class action lawsuit seeking monetary and injunctive relief under state law arising from the misreporting of pricing data to the USDA, where the data in turn were used to set a minimum price structure for raw milk sales; and (2) if the doctrine was applicable in that situation, whether the district court erred when it dismissed Plaintiffs' state causes of action on the ground that the filed rate doctrine barred such claims, even though the court found that it was not disputed that the USDA determined that the rates calculated were erroneous and that other rates should have applied based on correct pricing inputs. The plaintiffs here were dairy farmers who sold raw milk that was priced according to the erroneous reports. The Ninth Circuit Court of Appeals reversed and remanded, holding that the district court properly determined that the filed rate doctrine applied to the minimum milk pricing program, but erred by concluding that the doctrine applied to bar the plaintiffs' state-law claims in this case. View "Carlin v. DairyAmerica, Inc." on Justia Law