Hawaii v. Standard Oil Co. presented a question of first impression: Whether a state, in its capacity as parens patriae, may maintain a private antitrust action under Section 4 of the Clayton Act to recover treble damages for injury to its general economy. Although Hawaii appears to be on solid ground in its assertion that it has an interest separate and distinct from its citizens, the Ninth Circuit held that injury to the general economy is too remote and indirect to give the state standing to sue and is not "injury to business or property" within the meaning of the statute.
Parens Patriae Action under Section Four of the Clayton Act,
22 Hastings L.J. 996
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