United States v. Trans-Missouri Freight Association

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]

United States v. Trans-Missouri Freight Association
Supreme Court of the United States
Argued December 8–9, 1896
Decided March 22, 1897
Full case nameUnited States v. Trans-Missouri Freight Association
Citations166 U.S. 290 (more)
17 S. Ct. 540; 41 L. Ed. 1007; 1897 U.S. LEXIS 2025
Case history
Prior53 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
MajorityPeckham, joined by Fuller, Harlan, Brewer, Brown
DissentWhite, joined by Field, Gray, Shiras
Laws applied
Sherman Antitrust Act of 1890

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]

See also

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


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