United States v. E. C. Knight Co.
|United States v. E.C. Knight Co.|
|Argued October 4, 1894
Decided January 21, 1895
|Full case name||United States v. E.C. Knight Co.|
|Citations||156 U.S. 1 (more)
15 S.Ct 249 (1895)
|Manufacturing is not considered an area that can be regulated by Congress pursuant to the commerce clause.|
|Majority||Fuller, joined by Brewer, Brown, Field, Gray, Shiras, White, Peckham|
|U.S. Const. Art. I, Sec 8.|
United States v. E. C. Knight Co., 156 U.S. 1 (1895), 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.
In 1890, the United States Congress enacted the Sherman Antitrust Act. As trusts significantly reduced competition between businesses, the act sought to curb such concentrations of power. One of its two main provisions outlawed all trade combinations or agreements that severely restricted trade between states or with foreign powers. The second outlawed any attempts to monopolize trade within the United States. When the American Sugar Refining Company acquired almost all of the sugar-producing capacity in the U.S., the government sought to divest it of its monopoly.
In 1892, the American Sugar Refining Company gained control of the E. C. Knight Company and several others which resulted in a 98% monopoly of the American sugar refining industry. President Grover Cleveland, in his second term of office (1893–1897), directed the national 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 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 monopolies would need to be taken by individual states, making such regulation extremely difficult with regards to out-of-state monopolies because states are prohibited from discriminating against out-of-state goods by, among other things, the Dormant Commerce Clause and Article I section 10 of the U.S. Constitution. The ruling prevailed until the end of the 1930s, when the court took a different position on the national government's power to regulate the economy.
Although the decision was never expressly overturned, the Court later retreated from this position in a series of cases (see for example Swift and Company v. United States) 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.
- List of United States Supreme Court cases, volume 156
- Commerce Clause
- History of the United States (1865-1918)
- Corporate personhood
- Sugar refining
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