Supreme Court Holds That Price Squeeze Claims Are Not Cognizable Absent a Duty to Deal at the Wholesale Level

On February 25, 2009, the Supreme Court issued a unanimous decision in Pacific Bell Tel. Co. d/b/a AT&T California v. linkLine Commc'ns, Inc. Resolving a split among the lower courts, the Court held that a price-squeeze claim may not be brought under Section 2 of the Sherman Act unless the defendant has an antitrust duty to deal with the plaintiff at wholesale. The Court also clarified that the pleading standards announced in Twombly, which arose in the conspiracy Section 1 context, apply to Section 2 monopolization claims.