In the case of J. Truett Payne Co., Inc. v. Chrysler Motors Corp., 1980, the U.S Supreme Court ruled that a plaintiff seeking damages for lost profits due to an antitrust violation does not need to prove the exact amount of damage suffered but rather provide a just and reasonable estimate based on relevant data available in court records or produced by reliable means. The decision came after J.Truett Payne Company, an automobile dealership, sued Chrysler Motors Corporation alleging that it had violated federal antitrust laws which resulted in substantial loss of potential profits for them over several years. The jury found Chrysler guilty; however, they awarded no damages as they were unable to determine their extent with sufficient precision.

In the dissenting opinion for J. Truett Payne Co., Inc. v. Chrysler Motors Corp., Justice Powell, joined by Chief Justice Burger and Justice Stewart, disagreed with the majority's view on how damages should be calculated in antitrust cases. They argued that the Court's decision to allow an estimation of damages without requiring precise calculations could lead to speculative and potentially excessive awards that go beyond compensating actual harm suffered by plaintiffs. The dissenters believed this approach contradicted established legal principles which require a clear demonstration of causation between defendant’s wrongful conduct and plaintiff’s alleged injury before any recovery can be made under federal antitrust laws. In their view, allowing juries to estimate damages would undermine these important safeguards against unjust enrichment at defendants' expense.