Associated General Contractors of Calif., Inc. v. California State Council of Carpenters
In Associated General Contractors of Calif., Inc. v. California State Council of Carpenters, 459 U.S. 519, 103 S.Ct. 897, 74 L.Ed.2d 723 (1983), the Supreme Court addressed the topic of standing when a number of labor unions alleged that a multiemployer association coerced its members and certain third parties to do business with nonunion firms.
While noting the difficulty in clearly stating standards for determining standing and comparing the level of difficulty of such a task to the articulation of a standard that adequately contains the concept of proximate cause, the Court discussed several factors relevant to determining whether a party has standing to raise federal antitrust claims:
(1) the causal connection between the alleged antitrust violation and the harm to the plaintiff;
(2) the existence of an improper motive;
(3) whether the injury was of a type that Congress sought to redress with the antitrust laws;
(4) the directness of the connection between the injury and the alleged restraint in the relevant market;
(5) the speculative nature of the damages;
(6) the risk of duplicative recoveries or complex apportionment of damages. Id. at 537-45, 103 S.Ct. at 908-12.