United States v. E.C. Knight Co. case brief

United States v. E.C. Knight Co. case brief summary

156 U.S. 1 (1895)

CASE SYNOPSIS

Plaintiffs appealed from the Circuit Court of Appeals for the Third Circuit which found that defendants did not violate the provision of an act of Congress, 26 Stat. 209 (1890), because they did not make contracts which restrained trade and commerce in the sale of refined sugar.

CASE FACTS
Plaintiffs, the United States and others, filed a bill charging that defendants, four sugar refinery companies, had violated the provisions of 26 Stat. 209 (1890), which protected trade and commerce against unlawful restraints and monopolies. The bill charged that contracts under which purchases of stock were made constituted combinations in restraint of trade. The bill sought cancellation of the agreements under which the stock was transferred and redelivery of stock. The circuit court dismissed the bill.

DISCUSSION

• On appeal, the court affirmed finding there was nothing which indicated any intention by defendants to put a restraint upon trade or commerce. 
• The fact that commerce was indirectly affected was not enough to entitle plaintiffs to the bill. 
• The act only authorized the courts to restrain violations in respect to contracts, combinations, or conspiracies in restraint of interstate or international trade or commerce. 
• Plaintiffs sought surrender of property which had already passed.

CONCLUSION

On appeal, the court affirmed and found that there was nothing which indicated any intention by defendants to put a restraint upon trade or commerce.