Hanover Shoe, Inc. v. United Shoe Mach. Corp

In Hanover Shoe, Inc. v. United Shoe Mach. Corp., 392 U.S. 481, 88 S.Ct. 2224, 20 L.Ed.2d 1231 (1968), the Court held that a Clayton Act defendant could not assert a defense that the plaintiff had suffered no "injury" because it had passed on any illegal overcharges to consumers. Illinois Brick Co. v. Illinois, 431 U.S. 720, 746, 97 S.Ct. 2061, 2075, 52 L.Ed.2d 707 (1977) subsequently made this "direct purchaser" rule bilateral, i.e., that case held that a state, the indirect purchaser of concrete block, could not pursue price-fixing claims against manufacturers--only the direct purchasers, masonry contractors, could pursue such claims.