United States V. E.c. Knight

Photo of a sugar refinery in the American south at the turn of the 20th century.
The 1895 case U.South. 5. Eastward. C. Knight dealt with the federal government'southward endeavor to enforce the Sherman Antitrust Act confronting a saccharide manufacturer. To a higher place, a sugar refinery in the American south at the turn of the 20th century.

Reproduction courtesy of the Library of Congress

United States v. East. C. Knight (1895)

In The states v. E. C. Knight (1895), the Supreme Court interpreted the Sherman Antitrust Act of 1890, which was designed to limit the dangerous growth of corporate monopoly in the last quarter of the 19th century. The deed provided that "every person who shall monopolize, or attempt to monopolize, or combine or conspire with any other person or persons, to monopolize any part of the merchandise or commerce among the several States ... shall be deemed guilty of a felony."

The case involved the American Sugar Refining Visitor. Not long after the Sherman Act was passed, American Sugar bought out four other sugar refineries, increasing its command over national sugar production to 98 percent. In response, the U.South. authorities sought to invalidate American Sugar'due south purchase in a lower federal court on the grounds that it violated the Sherman Act. The lower court dismissed the case, and the authorities appealed to the Supreme Court.

In an 8-1 decision written by Principal Justice Melville W. Fuller, the Courtroom ruled that the authorities lacked power under the Constitution to enforce the Sherman Act against the visitor'due south manufacturing operations. Congress's powers are limited to those enumerated in the Constitution, the Court argued, and merely 1 of those powers, that given by the Constitution'due south Commerce Clause, allows Congress to "regulate commerce ... among the several States." Manufacturing operations are not "interstate commerce," the Court asserted, because such operations occur entirely in one land. In curt, Congress has the ability to regulate merchandise only not manufacturing.

In formulating its ruling, the Court attempted to reconcile Congress's powers under the Commerce Clause with the economic realities of the industrial historic period. By the late 19th century, every bit the American economy became more national in scope, and the Court felt obligated to "describe a line" between commercial activities that are "mercantile" in nature, which Congress could regulate, and those "industrial" in nature, which the Court ruled Congress could non regulate. The Commerce Clause only permitted federal regulation of the buying, selling, and transportation of goods between states. If the authorities were likewise permitted to regulate the product of goods, equally it attempted to exercise in this case, "insufficiently lilliputian of business operations would be left for state control."

Like Lochner 5. New York (1905), Us v. E. C. Knight proved to exist a serious obstacle to the New Bargain reforms during the Great Depression. Also like Lochner, Knight was effectively overturned by the late 1930s. In Due north.L.R.B. five. Jones & Laughlin Steel Corp. (1937), the Supreme Courtroom ruled that an in-state commercial activity like manufacturing may be deemed a office of interstate commerce if the activity has a "close and substantial relationship" to interstate commerce. The Jones & Laughlin determination opened the door for expansive federal regulation of the economic system. Judging past U.South. v. Lopez (1995), nevertheless, the Court's permissive arroyo to congressional authority under the commerce clause may be coming to an end.


	Writer'S BIO

	Alex McBride is a third yr police student at Tulane Law School in New Orleans. He is articles editor on the TULANE Constabulary REVIEW and the 2005 recipient of the Ray Forrester Award in Constitutional Law. In 2007, Alex will exist clerking with Judge Susan Braden on the United States Court of Federal Claims in Washington.