American Telephone & Telegraph Co. v. Central Office Telephone, Inc.

Summary

The Court, in an opinion by Justice Scalia, held that the Communications Act's filed rate doctrine bars COT's state-law claims seeking services and privileges inconsistent with AT&T's filed tariff. The doctrine covers nonprice terms, including provisioning and billing, and bars the wholly derivative tortious-interference claim as well as the contract claim. Neither the Act's saving clause nor the tariff's exception for willful misconduct permits enforcement of unlawful preferences. Chief Justice Rehnquist concurred separately, without any justice joining his writing, emphasizing that the doctrine does not bar independent state-law claims unrelated to tariffed terms. Justice Stevens dissented alone, arguing that evidence of unauthorized customer transfers and billing disclosures supported an independent tort claim and that the case should be remanded for a new trial. Justice O'Connor did not participate.