United States v. E. C. Knight Co.

United States v. E. C. Knight Co., 156 U.S. 1 (1895), is a landmark decision of the United States Supreme Court.

The federal government sought to block the American Sugar Refining Company’s acquisition of the E. C. Knight Company, arguing that the acquisition violated the Sherman Antitrust Act by creating a monopoly in sugar refining. The government argued that sugar manufacturing affected interstate commerce.

Significance

The Supreme Court held that manufacturing was a local activity, not interstate commerce, and thus fell outside federal power under the Sherman Act. Chief Justice Fuller distinguished between ‘manufacturing’ (local) and ‘commerce’ (interstate), creating a narrow interpretation of the Commerce Clause that limited federal regulatory power over the economy for decades. The decision hampered antitrust enforcement and was eventually limited by later New Deal-era cases expanding the definition of interstate commerce.

Category

US Federal Case Law