Bigelow v. RKO Radio Pictures, Inc., 327 U.S. 251 (1946), was a decision by the United States Supreme Court allowing an action to recover compensatory damages under the antitrust statutes.

The jury had returned a verdict for $120,000 in petitioner's favor, covering a five-year period where plaintiff suffered due to respondents' antitrust conspiracy.

The 7th Circuit reversed on the sole ground that the evidence of damage was not sufficient for submission to the jury, and directed the entry of judgment for respondents non obstante veredicto (notwithstanding the verdict).

During the conspiracy, films were distributed among cinemas in Chicago in such a manner that theatres owned by some of the conspirators were able to show movies before independent theater operators.

The 7th Circuit concluded that the jury had adopted the before & after method, but that this proof did not furnish a proper measure of damage for the reason that it could not be proved what petitioner's earnings would have been in the absence of the illegal distribution of films.