Nevada Recycling & Salvage, Ltd. v. Reno Disposal Co., Inc.
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The Supreme Court affirmed the district court’s order granting summary judgment in favor of Respondents on Appellants’ claim that Respondents conspired with a third party to obtain exclusive franchise agreements with the City of Reno for the collection of waste and recyclable materials, holding that Appellants lacked standing to assert their claim under the Nevada Unfair Trade Practice Act (UTPA) because they were unable to show that they suffered any injuries.
Appellants claimed that Respondents’ conspiracy with the third party precluded them from receiving a franchise agreement with the City. The district court concluded that, in terms of damages, Appellants lacked standing to assert a UTPA claim because they were not qualified to service a franchise zone, they never sought to be considered for a franchise zone, and the City determined that they were not qualified waste haulers. The Supreme Court affirmed, holding that Appellants lacked antitrust standing because they did not make any showing that they suffered any injuries from Respondents’ alleged conspiracy.
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