Key Findings: Fourth Circuit Affirms Summary Judgment in Railroad Case, Holds Sherman Act Claims Are Time Barred


On August 29, 2024, the US Court of Appeals for the Fourth Circuit affirmed the district court’s grant of summary judgement, holding that Sherman Act claims brought by CSX Transportation against Norfolk Southern and Belt Line are time barred (CSX Transportation, Inc. v. Norfolk S. Ry. Co., 2024 WL 3974989 (4th Cir. Aug. 29, 2024)). The Fourth Circuit agreed with the district court that the statute of limitations expired, and that the continuing violation doctrine does not apply.

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