• Connecticut Supreme Court
  • Connecticut Supreme Court
  • SC 18811
  • Jun 04 2013 (Date Decided)
  • Zarella, J.

As explained in the 2010 Connecticut Supreme Court case of Valvo v. Freedom of Information Commission, "[a] case is considered moot if the …court cannot grant the appellant any practical relief through its disposition of the merits." Wyatt Energy, Inc. unilaterally terminated an agreement with Motiva Enterprises, LLC, granting Motiva exclusive use of logistical and storage services provided by a gasoline distribution terminal owned by Wyatt, after Motiva purchased a competing terminal owned by Cargill, Inc. Wyatt then sold its terminal to Williams Energy without requiring Williams to assume Wyatt's obligations under the agreement with Motiva. Wyatt filed a complaint against Motiva and Motiva responded with a counterclaim, each claiming breach of contract by the other party. Wyatt asserted a special defense of illegality premised on purported antitrust violations arising out of Motiva's purchase of Cargill's terminal. Ultimately, the trial court rejected the special defense and found for Motiva. The Appellate Court affirmed the judgment. Wyatt appealed claiming that the Appellate Court improperly based its affirmance of the trial court's judgment on a flawed antitrust analysis that relied on legally incorrect definitions of the product and geographic markets served by the Wyatt terminal. The Supreme Court dismissed the appeal, agreeing with Motiva's alternative ground for affirmance, that the issue raised regarding the proper definition of the product and geographic market was moot because Wyatt did not appeal from the trial court's finding that excess capacity and other competitive factors would have prevented Motiva from imposing higher, noncompetitive prices for the services supplied by Wyatt. Even assuming that Wyatt's definitions of the product and geographic markets were correct, no practical relief could be offered to Wyatt. The trial court's unchallenged findings that there was substantial excess capacity in both coastal Connecticut and Connecticut as a whole would have supported the trial court's conclusion that Motiva's acquisition of the Cargill terminal did not give Motiva the opportunity to exercise market power or to engage in actual or attempted monopolization in violation of C.G.S. §35-26 and §35-27.