In re January 2021 Short Squeeze Trading Litigation (Antitrust Tranche)
U.S. District Court for the Southern District of Florida (MDL); U.S. Court of Appeals for the Eleventh Circuit
- Court
- U.S. District Court for the Southern District of Florida (MDL); U.S. Court of Appeals for the Eleventh Circuit
- Docket
- MDL No. 1:21-md-02989 (S.D. Fla.); No. 22-11873 (11th Cir.)
- Parties
- Angel Guzman and other retail investors v. Robinhood Markets, Inc., Robinhood Financial LLC, Robinhood Securities, LLC, and Citadel Securities
- Claim type
- antitrust
- Filed
- 2021
- Outcome
- District court (Chief Judge Cecilia M. Altonaga) dismissed the antitrust conspiracy claims; the Eleventh Circuit affirmed on June 26, 2024, holding plaintiffs failed to plausibly allege an unreasonable restraint of trade or anticompetitive effects in the pleaded markets.
Summary
After Robinhood and other brokers restricted buying of GameStop and other meme stocks on January 28, 2021, dozens of suits were consolidated into a multidistrict litigation in the Southern District of Florida before Chief Judge Cecilia M. Altonaga. The antitrust tranche alleged Robinhood and Citadel Securities conspired under Sherman Act Section 1 to halt retail buying so Citadel could cover short positions at deflated prices. Judge Altonaga dismissed the claims, and on June 26, 2024 the Eleventh Circuit affirmed, holding that the alleged harm was not an anticompetitive effect in the plaintiffs' defined markets. The episode was driven heavily by Reddit's r/WallStreetBets community.