NationMaster - Encyclopedia: United States v. E. C. Knight Co.

United States v. E. C. Knight Co., 156 U.S. 1 (1895)^[1], 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 decision was issued on January 21, 1895. Melville Weston Fuller (February 11, 1833 â€“ July 4, 1910) was the Chief Justice of the United States between 1888 and 1910. ... Stephen Johnson Field (November 4, 1816 – April 9, 1899) was an associate justice of the United States Supreme Court from May 20, 1863, to December 1, 1897. ... John Marshall Harlan John Marshall Harlan (June 1, 1833 â€“ October 14, 1911) was an American Supreme Court associate justice. ... Horace Gray (March 24, 1828-September 15, 1902) was an American jurist. ... David Josiah Brewer (January 20, 1837-March 28, 1910), was an American jurist. ... Categories: People stubs | U.S. Supreme Court justices | U.S. District Court judges | American lawyers | 1836 births | 1913 deaths ... Justice Shiras, 1900 George Shiras, Jr. ... Chief Justice Edward Douglass White took the office in 1910. ... This article is about the Associate Justice of the U.S. Supreme Court; for Justice Peckhams father of the same name who served in the U.S. House of Representatives, see Rufus Wheeler Peckham (1809-1873). ... // Case citation is the system used in common law countries such as the United States, England and Wales, Canada, New Zealand Australia and India to uniquely identify the location of past court cases in special series of books called reporters. ... 1895 (MDCCCXCV) was a common year starting on Tuesday (see link for calendar) of the Gregorian calendar (or a common year starting on Thursday of the 12-day-slower Julian calendar). ... This is a chronological list of notable cases decided by the Supreme Court of the United States. ... The Sherman Anti-Trust Act, formally known as the Act of July 2, 1890, ch. ... October 24 is the 297th day of the year (298th in leap years) in the Gregorian Calendar, with 68 days remaining. ... 1894 (MDCCCXCIV) was a common year starting on Monday (see link for calendar). ... January 21 is the 21st day of the year in the Gregorian calendar. ... 1895 (MDCCCXCV) was a common year starting on Tuesday (see link for calendar) of the Gregorian calendar (or a common year starting on Thursday of the 12-day-slower Julian calendar). ...

1 Background
2 The Bench
- 2.1 Opinion
- 2.2 Dissenting
3 The Case
4 The Decision
5 Later developments
6 External links
7 See also

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. When the E.C. Knight Company acquired almost all of the sugar-producing capacity in the U.S., the government sought to divest it of its monopoly. 1890 (MDCCCXC) was a common year starting on Wednesday (see link for calendar) of the Gregorian calendar (or a common year starting on Friday of the Julian calendar). ... Congress in Joint Session. ... The Sherman Anti-Trust Act, formally known as the Act of July 2, 1890, ch. ...

Argued: October 24, 1894 Decided: January 21,1895

The Bench

Opinion

Written by: Chief Justice Melville W. Fuller

Joined by: Justices Stephen J. Field, Horace Gray, David J. Brewer, Henry B. Brown, George Shiras, Jr., Howell E. Jackson and Edward D. White

The Chief Justice of the United States is the head of the judicial branch of the government of the United States, and presides over the Supreme Court of the United States. ... Melville Weston Fuller (February 11, 1833–July 4, 1910) was the Chief Justice of the United States between 1888 and 1910. ... Associate Justices of the United States Supreme Court are the members of that court other than the Chief Justice. ... Stephen Johnson Field (November 4, 1816 – April 9, 1899) was an associate justice of the United States Supreme Court from May 20, 1863, to December 1, 1897. ... Horace Gray (March 24, 1828-September 15, 1902) was an American jurist. ... David Josiah Brewer (January 20, 1837-March 28, 1910), was an American jurist. ... Categories: People stubs | U.S. Supreme Court justices | U.S. District Court judges | American lawyers | 1836 births | 1913 deaths ... Justice Shiras, 1900 George Shiras, Jr. ... Howell Edmunds Jackson (April 8, 1832–August 8, 1895) was an American jurist and politician. ... Chief Justice Edward Douglass White took the office in 1910. ...

Dissenting

Written by: Justice John M. Harlan

John Marshall Harlan John Marshall Harlan (June 1, 1833 â€“ October 14, 1911) was an American Supreme Court associate justice. ...

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? 1892 (MDCCCXCII) was a leap year starting on Friday (see link for calendar). ... Stephen Grover Cleveland (March 18, 1837 â€“ June 24, 1908) was the 22nd (1885â€“1889) and 24th (1893â€“1897) President of the United States, and the only President to serve two non-consecutive terms. ... 1893 (MDCCCXCIII) was a common year starting on Sunday (see link for calendar). ... 1897 (MDCCCXCVII) was a common year starting on Friday (see link for calendar). ...

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. January 21 is the 21st day of the year in the Gregorian calendar. ... 1895 (MDCCCXCV) was a common year starting on Tuesday (see link for calendar) of the Gregorian calendar (or a common year starting on Thursday of the 12-day-slower Julian calendar). ... The Chief Justice of the United States is the head of the judicial branch of the government of the United States, and presides over the Supreme Court of the United States. ... Melville Weston Fuller (February 11, 1833–July 4, 1910) was the Chief Justice of the United States between 1888 and 1910. ... The Justices of the United States Supreme Court, other than the Chief Justice, are termed Associate Justices. ... John Marshall Harlan John Marshall Harlan (June 1, 1833 â€“ October 14, 1911) was an American Supreme Court associate justice. ...

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. Theodore Roosevelt, Jr. ... William Howard Taft (September 15, 1857 â€“ March 8, 1930) was an American politician, the 27th President of the United States, the 10th Chief Justice of the United States, and a leader of the conservative wing of the Republican Party. ... Trust-busting refers to government activities designed to break up trusts or monopolies. ...

Later developments

Although the decision was never expressly overturned, the Court later retreated from this position in a series of cases that defined various steps of the manufacturing process as part of commerce. Eventually, E.C. Knight came to be a precedent narrowed to its precise facts, with no force whatsoever.

External links

↑ 156 U.S. 1 (Text of the opinion on Findlaw.com.)
Full text of the decision & case resources from Justia & Northwestern-Oyez

Contents

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