On October 6, 2016, in Wallen v. St. Louis Metropolitan Taxicab Commission, the US District Court for the Eastern District of Missouri denied a motion to dismiss antitrust claims brought by Uber and potential Uber drivers and users against the Metropolitan Taxicab Commission of Metropolitan St. Louis (MTC) and individual commission members (No. 15-cv-1432, (E.D. Mo. Oct. 6, 2016)). The court held that the MTC was not immune from suit under the state action doctrine. The court granted motions to dismiss brought by individual taxi company defendants.

The plaintiffs alleged that the defendants, which include the Metropolitan Taxicab Commission of Metropolitan St. Louis (MTC), individual members of the commission, and taxi companies, acted to prohibit Uber from operating in the St. Louis for-hire transportation market, in violation of Section 1 of the Sherman Act. The plaintiffs claim that the defendants stifled competition by:

The MTC, its chairman, and three individual members (who each own taxi companies) claimed immunity from suit under the state action doctrine. The state action doctrine immunizes local government entities such as cities from antitrust liability when they act pursuant to a clearly articulated state policy to limit competition (see Practice Note, State Action Doctrine). The court noted that to claim state action immunity the defendants were required to show that:

The court focused on the clear articulation requirement. The MTC defendants argued that the state granted the MTC powers that indicated a clear articulation of a policy permitting anticompetitive conduct. The MTC's enumerated powers include, among other things, the right to:

The court, however, found that nothing in the MTC's enumerated powers indicated that the state intended to allow anticompetitive conduct. Instead, the court found that the MTC's purpose is to provide a safe and efficient transportation system, which did not require displacing competition. As a result, the taxi commission defendants were not entitled to state action immunity.

The complaint also alleged that the taxi companies owned by the MTC commissioners were co-conspirators in the alleged antitrust violations. The taxi company defendants sought dismissal because they claimed the plaintiffs:

The court agreed that the complaint contained no allegations supporting imputing the actions of the individual MTC commissioners to the taxi companies that they owned. The court granted these defendants' motions to dismiss for failure to state a claim.