United States v. Trans-Missouri Freight Association

United States v. Trans-Missouri Freight Association
Supreme Court of the United States
Argued December 8–9, 1896 Decided March 22, 1897
Full case name	United States v. Trans-Missouri Freight Association
Citations	166 U.S. 290 (more) 17 S. Ct. 540; 41 L. Ed. 1007; 1897 U.S. LEXIS 2025
Case history
Prior	53 F. 440 (C.C.D. Kan. 1892); affirmed, 58 F. 58 (8th Cir. 1893).
Court membership
Chief Justice Melville Fuller Associate Justices Stephen J. Field · John M. Harlan Horace Gray · David J. Brewer Henry B. Brown · George Shiras Jr. Edward D. White · Rufus W. Peckham
Case opinions
Majority	Peckham, joined by Fuller, Harlan, Brewer, Brown
Dissent	White, joined by Field, Gray, Shiras
Laws applied
Sherman Antitrust Act of 1890

United States v. Trans-Missouri Freight Association, 166 U.S. 290 (1897), was a United States Supreme Court case holding that the Sherman Act (which was an antitrust measure that prohibited anticompetitive behavior in commerce) applied to the railroad industry, even though the U.S. Congress had enacted a comprehensive regime of regulations for that industry.^[1]

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Transcription

Background

Various railroad companies had formed an organization to regulate prices charged for transportation. The federal government charged these companies with violating the Sherman Act, and the railroad companies replied that they were not in violation of the act because their organization was designed to keep prices low, not to push them higher. The companies also contended that Congress had not intended the Sherman Act to apply to them, because there were already a wide array of laws governing the railroads.

Opinion of the Court

The Supreme Court held that the Sherman Act prohibited all such combinations, irrespective of the purpose. The railroad association was price fixing under the per se approach. Competition should determine the reasonable rate, not agreements between companies.^[2] The court further held that congressional debate could not be used to decipher legislative intent due to the complex and often varying opinions on what the act means for different legislators^[3]

v t e Sources on rule of reason
US v. Trans-Missouri Freight Asn, 166 U.S. 290 (1897)
US v. Joint Traffic Association, 171 U.S. 505 (1898)
Addyston Pipe and Steel Co. v. US, 175 U.S. 211 (1899)
Standard Oil Co. of New Jersey v. US, 221 U.S. 1 (1911)
Chicago Board of Trade v. US, 246 U.S. 231 (1918)
United States v. Topco Assocs., Inc., 405 U.S. 596 (1972)
National Soc. of Prof. Engineers v. US, 435 U.S. 679 (1978)
Broadcast Music v. Columbia Broadcast, 441 U.S. 1 (1979)
Broadcast Music, Inc. v. CBS, Inc., 441 U.S. 1 (1979)
Arizona v. Maricopa County Med Soc, 457 U.S. 332 (1982)
NCAA v. University of Oklahoma, 468 U.S. 85 (1984)
FTC v. Indiana Fed'n of Dentists, 476 U.S. 447 (1986)
Palmer v. BRG of Georgia, Inc., 498 U.S. 46 (1990)
California Dental Assn. v. FTC, 526 U.S. 756 (1999)
See US antitrust law and rule of reason

References

^ United States v. Trans-Missouri Freight Ass'n, 166 U.S. 290 (1897).
^ Tally, J. O. "The Supreme Court, the Interstate Commerce Commission and the Freight Rate Battle". North Carolina Law Review. 25 (2): 189.
^ Landry, Michael; Stone. "The Trans-Missouri Case: Does the Sherman Act Apply to Railroads?". Essays in Economic & Business History. 21: 132–133.

External links

Works related to United States v. Trans-Missouri Freight Association at Wikisource
Text of United States v. Trans-Missouri Freight Association, 166 U.S. 290 (1897) is available from: Justia Library of Congress

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This page was last edited on 13 September 2023, at 03:22

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