Editing United States v. E. C. Knight Co.

{{Use mdy dates|date=September 2023}}
{{Primary sources|date=November 2019}}
{{Infobox SCOTUS case
  | Litigants               = United States v. E.C. Knight Co.
  | ArgueDate               = October 4
  | ArgueYear               = 1894
  | DecideDate              = January 21
  | DecideYear              = 1895
  | FullName                = United States v. E.C. Knight Co.
  | USVol                   = 156
  | USPage                  = 1
  | ParallelCitations       = 15 S. Ct 249; 39 [[L. Ed.]] 325; 1895 [[U.S. LEXIS]] 2118
  | Prior                   = 60 [[Federal Reporter|F.]] 306 ([[United States circuit court|C.C.E.D. Pa.]] 1894); affirmed, 60 F. 934 ([[3d Cir.]] 1894)
  | Subsequent              = 
  | Holding                 = Manufacturing is not considered an area that can be regulated by Congress pursuant to the commerce clause.
  | Majority                = Fuller
  | JoinMajority            = Field, Gray, Brewer, Brown, Shiras, Jackson, White
  | Concurrence             = 
  | JoinConcurrence         = 
  | Concurrence2            = 
  | JoinConcurrence2        = 
  | Concurrence/Dissent     = 
  | JoinConcurrence/Dissent = 
  | Dissent                 = Harlan
  | JoinDissent             = 
  | Dissent2                = 
  | JoinDissent2            = 
  | LawsApplied             = 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]] [[United States antitrust law|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 [[U.S. Congress]] could not regulate manufacturing and thus gave state governments the sole power to take legal action against manufacturing [[Monopoly|monopolies]].<ref name=":0">{{ussc|name=United States v. E. C. Knight Co.|link=|volume=156|page=1|pin=|year=1895}}.</ref> 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]].

==The case==
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. [[U.S. President]] [[Grover Cleveland]], in his second term of office (1893&ndash;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 (business)|distribution]]''?"

==The decision==
[[File:Justices of the Supreme Court of the United States, October 1894.jpg|thumb|alt=The [[Fuller Court]].|The [[Fuller Court]].]]
The court's 8–1 decision, handed down on January 21, 1895 and written by [[Chief Justice of the United States|Chief Justice]] [[Melville Weston Fuller]], went against the government. [[Associate Justice of the United States Supreme Court|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"<ref name=":0"/> but ruled that it "could not be suppressed under the provisions of the act."<ref name=":0" />

The Court ruled that manufacturing, in this case, refining, was a local activity, not subject to congressional regulation of interstate commerce. Fuller wrote:

<blockquote>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.&nbsp;.&nbsp;.&nbsp;. Doubtless the power to control the manufacture of a given thing involves in a certain sense the control of its disposition, but .&nbsp;.&nbsp;. affects it only incidentally and indirectly.</blockquote>

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|date=February 2021}}

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]]''. .<ref name=":0" />

==Later developments==
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|date=February 2021}}

==See also==
*[[Antitrust]]
*[[Commerce Clause]]
*{{C|Sugar companies of the United States}}
*[[Sugar industry of the United States]]
**[[Sugar refining]]
**[[Sugarcane]]

==References==
{{Reflist}}

==External links==
*{{wikisource-inline|United States v. E. C. Knight Company}}
* {{caselaw source
 | case = ''United States v. E. C. Knight Co.'', {{ussc|156|1|1895|el=no}}
 | cornell =https://www.law.cornell.edu/supremecourt/text/156/1
 | justia =https://supreme.justia.com/cases/federal/us/156/1/
 | loc =http://cdn.loc.gov/service/ll/usrep/usrep156/usrep156001/usrep156001.pdf
 }}

{{United States antitrust law|state=collapsed}}
{{USArticleI}}

{{DEFAULTSORT:United States V. E. C. Knight Co.}}
[[Category:Sugar industry of the United States]]
[[Category:1895 in United States case law]]
[[Category:United States Constitution Article One case law]]
[[Category:United States antitrust case law]]
[[Category:United States Commerce Clause case law]]
[[Category:United States Supreme Court cases of the Fuller Court]]
[[Category:United States Supreme Court cases]]