United States v. E. C. Knight Co., 156 U.S. 1 (1895), also known as the "Sugar Trust Case," was a United States Supreme Courtantitrust case that severely limited the federal government's power to pursue antitrust actions under the Sherman Antitrust Act. In Chief Justice Melville Fuller's majority opinion, the Court held that the US Congress could not regulate manufacturing and thus gave state governments the sole power to take legal action against manufacturing monopolies.[1] The case has never been overruled, but in Swift & Co. v. United States and subsequent cases, the Court has held that Congress can regulate manufacturing when it affects interstate commerce.
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. US PresidentGrover 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"[1] but ruled that it "could not be suppressed under the provisions of the act."[1]
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.
The decision required any action against manufacturing monopolies to be taken by individual states. The ruling prevailed until the end of the 1930s, when the Court took a different position on the federal government's power to regulate the economy.[citation needed]
In his dissent, Harlan argued "the doctrine of the autonomy of the states cannot properly be invoked to justify a denial of power in the national government to meet such an emergency." He continued to argue the Constitution gives Congress "authority to enact all laws necessary and proper" to regulate commerce and cited McCulloch v. Maryland. .[1]
Later developmentsedit
Although the decision was never expressly overturned, the Court later retreated from its position in a series of cases such as Swift and Company v. United States, which have 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 other force.[citation needed]
^ abcdUnited States v. E. C. Knight Co., 156U.S. 1 (1895).
External linksedit
Works related to United States v. E. C. Knight Company at Wikisource
Text of United States v. E. C. Knight Co., 156U.S. 1 (1895) is available from:CornellJustiaLibrary of Congress
May 09, 2024
united, states, knight, this, article, relies, excessively, references, primary, sources, please, improve, this, article, adding, secondary, tertiary, sources, find, sources, news, newspapers, books, scholar, jstor, november, 2019, learn, when, remove, this, m. This article relies excessively on references to primary sources Please improve this article by adding secondary or tertiary sources Find sources United States v E C Knight Co news newspapers books scholar JSTOR November 2019 Learn how and when to remove this message 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 antitrust case that severely limited the federal government s power to pursue antitrust actions under the Sherman Antitrust Act In Chief Justice Melville Fuller s majority opinion the Court held that the US Congress could not regulate manufacturing and thus gave state governments the sole power to take legal action against manufacturing monopolies 1 The case has never been overruled but in Swift amp Co v United States and subsequent cases the Court has held that Congress can regulate manufacturing when it affects interstate commerce United States v E C Knight Co Supreme Court of the United StatesArgued October 4 1894Decided January 21 1895Full case nameUnited States v E C Knight Co Citations156 U S 1 more 15 S Ct 249 39 L Ed 325 1895 U S LEXIS 2118Case historyPrior60 F 306 C C E D Pa 1894 affirmed 60 F 934 3d Cir 1894 HoldingManufacturing is not considered an area that can be regulated by Congress pursuant to the commerce clause Court membershipChief Justice Melville Fuller Associate Justices Stephen J Field John M HarlanHorace Gray David J BrewerHenry B Brown George Shiras Jr Howell E Jackson Edward D WhiteCase opinionsMajorityFuller joined by Field Gray Brewer Brown Shiras Jackson WhiteDissentHarlanLaws appliedU S Const Art I Sec 8 Contents 1 The case 2 The decision 3 Later developments 4 See also 5 References 6 External linksThe case editIn 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 US 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 decision edit nbsp The Fuller Court 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 1 but ruled that it could not be suppressed under the provisions of the act 1 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 The decision required any action against manufacturing monopolies to be taken by individual states The ruling prevailed until the end of the 1930s when the Court took a different position on the federal government s power to regulate the economy citation needed In his dissent Harlan argued the doctrine of the autonomy of the states cannot properly be invoked to justify a denial of power in the national government to meet such an emergency He continued to argue the Constitution gives Congress authority to enact all laws necessary and proper to regulate commerce and cited McCulloch v Maryland 1 Later developments editAlthough the decision was never expressly overturned the Court later retreated from its position in a series of cases such as Swift and Company v United States which have 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 other force citation needed See also editAntitrust Commerce Clause Sugar companies of the United States Sugar industry of the United States Sugar refining SugarcaneReferences edit a b c d United States v E C Knight Co 156 U S 1 1895 External links edit nbsp Works related to United States v E C Knight Company at Wikisource Text of United States v E C Knight Co 156 U S 1 1895 is available from Cornell Justia Library of Congress Retrieved from https en wikipedia org w index php title United States v E C Knight Co amp oldid 1217679846, wikipedia, wiki, book, books, library,
