American Sugar Refining Co. acquired nearly complete control over the manufacture of refined sugar in the U.S. when it bought out 4 sugar companies.
U.S. claimed that the purchases were in restraint of trade and commerce in violation of the Sherman Act.
Procedural History:
SCOTUS ruled against U.S., monopoly valid.
Issues:
Does Congress have the authority to suppress a manufacturing monopolies in the states?
Holding/Rule:
Congress does not have the authority to suppress a manufacturing monopoly since manufacturing is not a part of commerce.
Reasoning:
The power to protect the lives, health, and property of its citizens and to preserve good order and public morals has always been a state duty.
The power to control the manufacture of a given thing involves, in a certain sense, the control of its disposition, but this is a secondary, and not the primary, sense.
Commerce succeeds to manufacture, and is not a part of it.
The gov't may suppress monopoly only when it is a monopoly of commerce; this is not the case here.
Dissent:
Harlan
Preservation of just authority is the reason the people gave power to the gov't. The constitution which enumerates these rights should not be so rigidly interpreted.
Congress may remove unlawful obstructions of any kind to free course among the states. This is true even if it would interfere with a state's autonomy since the people have vested this power in the federal gov't.
Any act that disturbs or obstructs freedom in buying and selling articles manufactured to be sold to persons in other states directly affects the people of all states.
