United States v. E. C. Knight Co.
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United States v. E. C. Knight Co., Template:Ussc, also known as the "Sugar Trust Case", was a United States Supreme Court case that limited the government's power to control monopolies. The case, which was the first heard by the Supreme Court concerning the Sherman Antitrust Act, was argued on October 24, 1894 and the decided was issued on January 21, 1895.
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Background
In 1890, the US Congress enacted the Sherman Antitrust Act, an attempt to curb concentrations of economic power that significantly reduced competition between businesses. One of its two main provisions outlawed all trade combinations or agreements that severely restrict trade between states or with foreign powers. The second outlawed any attempts to monopolize trade within the United States.
The bench
Opinion
- Written by: Chief Justice Melville W. Fuller
Dissenting
- Written by: Justice John M. Harlan
The case
In 1892 the American Sugar Refining Company gained control of the E. C. Knight Company which itself controlled 98% of the American sugar refining industry. President Grover Cleveland, in his second term of office (1893–1897), directed the Federal government to sue the Knight Company under the provisions of the Sherman Antitrust Act to prevent the acquisition. The question the court had to answer was, could the Sherman Antitrust Act suppress a monopoly in the manufacture of a good, as well as its distribution?
The decision
The court's 8-1 decision, handed down on January 21, 1895 and written by Chief Justice Melville Weston Fuller, went against the government. Justice John Marshall Harlan dissented.
The court held "that the result of the transaction was the creation of a monopoly in the manufacture of a necessary of life" but ruled that it "could not be suppressed under the provisions of the act". The court ruled that manufacturing—in this case, refining—was a local activity not subject to congressional regulation of interstate commerce. Fuller wrote:
That which belongs to commerce is within the jurisdiction of the United States, but that which does not belong to commerce is within the jurisdiction of the police power of the State. . . . Doubtless the power to control the manufacture of a given thing involves in a certain sense the control of its disposition, but . . . affects it only incidentally and indirectly.
Under the Knight decision, any action against manufacturing combinations would need to be taken by individual states, making such regulation more difficult. It was not until the administrations of Theodore Roosevelt and William Howard Taft that serious trust-busting would take place by the federal government.
See also
- List of United States Supreme Court Cases
- Gibbons v. Ogden, Template:Ussc
- Antitrust
- Commerce Clause
- Corporate personhood
- History of the United States (1865-1918)
External links
- Full text of the decision courtesy of Findlaw.com (http://laws.findlaw.com/us/156/1.html)