Bid-rigging (in this case at foreclosure sales) is a form of horizontal price fixing and therefore is per se illegal under the Sherman Act.  The district court properly refused defendant’s effort to justify his violation by its allegedly ameliorative effects under the rule of reason test.

Ninth Circuit Court of Appeals (Murphy, J., sitting by designation); July 11, 2018; 2018 U.S. App. LEXIS 18922