University of Richmond Law Review Volume 28 | Issue 2 Article 7 1994 Brooke Group Ltd. v. Brown & Williamson Tobacco Corp.: A Victory for Consumer Welfare Under the Robinson-Patman Act Keith Allen May University of Richmond Follow this and additional works at: http://scholarship.richmond.edu/lawreview Part of the Consumer Protection Law Commons Recommended Citation Keith A. May, Brooke Group Ltd. v. Brown & Williamson Tobacco Corp.: A Victory for Consumer Welfare Under the Robinson-Patman Act, 28 U. Rich. L. Rev. 507 (1994). Available at: http://scholarship.richmond.edu/lawreview/vol28/iss2/7 This Note is brought to you for free and open access by the Law School Journals at UR Scholarship Repository. It has been accepted for inclusion in University of Richmond Law Review by an authorized editor of UR Scholarship Repository. For more information, please contact
[email protected]. CASENOTES BROOKE GROUP LTD. V. BROWN & WILLIAMSON TOBACCO CORP.: A VICTORY FOR CONSUMER WELFARE UNDER THE ROBINSON-PATMAN ACT* The need for clarity, obviously a desideratum for any body of law, has been evidenced by judicial recognition that Rob- inson-Patman is not to be viewed as an act of Congressional schizophrenia, an anti-competitive island situated in an otherwise turbulent sea of pro-competitive efficiency and maximization of consumer welfare, the hallmarks of the Nation's antitrustlaws. The Supreme Court warned early on of the dangers of doctrinaire interpretations of Robinson- Patman that could lead to "conflict with the purposes of other antitrust legislation." -Kenneth Starr' I. INTRODUCTION The preservation of competition among business entities is vital to the success of any economy.