Federal Law Held To Govern Effect of the Release of a Joint Tortfeasor in Private Antitrust Suit-Winchester Drive-in Theatre, Inc. v. Twentieth Century Fox Film Co.

Private antitrust litigation occasionally raises the question of whether state or federal law should be applied to determine the effect of the release of a joint tortfeasor. When federal law is applied, as it was in Winchester Drive-In Theatre, Inc. v. Twentieth Century-Fox Film Co., there remains the necessity of formulating a rule of federal law, since there appears to be no established federal rule governing releases in antitrust suits.