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Swift & Co. v. United States

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Supreme Court of the United States
Swift & Co. v. United States
Reference: 196 U.S. 375
Term: 1905
Important Dates
Argued: January 5-8, 1905
Decided: January 30, 1905
Outcome
United States District Court for the Northern District of Illinois affirmed
Majority
Chief Justice Melville Fuller • John M. Harlan • David J. Brewer • Henry B. Brown • Edward D. White • Rufus W. Peckham • Joseph McKenna • Oliver Holmes • William R. Day

Swift & Co. v. United States is a case decided on January 30, 1905, by the United States Supreme Court. It involved the regulation of the meat industry under the Commerce Clause. The Supreme Court held that the meat industry at large constituted interstate commerce and that joint efforts by six meatpacking companies, known as the "Beef Trust" or the "Big Six," to fix prices and obtain reduced transportation rates violated the Commerce Clause.[1][2][3]

HIGHLIGHTS
  • The case: The U.S. attorney general filed suit against a group of meatpacking companies for alleged monopolistic practices in violation of the Sherman Antitrust Act of 1890.
  • The issue: Was Congress authorized to regulate the meatpacking industry under the Sherman Antitrust Act?
  • The outcome: The Supreme Court held that the Big Six violated the Commerce Clause by engaging in monopolistic practices that impacted the interstate operations of the meat industry.


    • Why it matters: The Supreme Court's decision in Swift & Co. v. United States held that broad chains of commerce within an industry constituted interstate commerce. Though the defendants' business activities occurred in individual states, the interstate implications for the industry at large violated the Commerce Clause. The case broadened the federal government's regulatory purview and contributed to the passage of the Pure Food and Drug Act and the Meat Inspection Act the following year.[1]

    Background

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    At the turn of the 20th century, six Chicago meatpacking companies, known as the "Beef Trust" or the "Big Six," agreed to cease bidding against one another in an effort to fix industry prices and control livestock shipments across state lines. The companies also negotiated rebates with railroad companies for reduced transportation rates. In 1902, President Theodore Roosevelt (R) called on U.S. Attorney General Philander Knox to file a lawsuit against the Big Six on the grounds that the group's actions constituted a monopoly and violated antitrust laws under the Sherman Antitrust Act of 1890. The Act placed broad prohibitions on activities that restrict interstate or international commerce and established felony penalties for monopolies.[1][4]

    Knox filed suit against the Big Six in the United States Circuit Court for the Northern District of Illinois, which overruled the demurrers of the defendants and issued a preliminary injunction to halt the companies' participation in monopolistic practices. The Big Six appealed the circuit court's ruling to the Supreme Court.[5]

    Oral argument

    Oral arguments were held from January 6 to January 8, 1905. The case was decided on January 30, 1905.[1]

    Outcome

    The Supreme Court ruled unanimously against the Big Six. The majority opinion was written by Justice Oliver Holmes.[2][1]

    Opinions

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    Opinion of the court

    Writing for the unanimous court, Justice Oliver Holmes argued that the cooperative efforts between the Big Six to fix prices and reduce transportation costs violated the Commerce Clause. Though the Big Six's distinct business practices occurred within individual states, they had broader implications for interstate commerce and the industry as a whole:[2]

    “ So far, it has not been necessary to consider whether the facts charged in any single paragraph constitute commerce among the States or show an interference with it. There can be no doubt, we apprehend, as to the collective effect of all the facts, if true, and if the defendants entertain the intent alleged. ... The purchasers and their slaughtering establishments are largely in different States from those of the stockyards, and the sellers of the cattle, perhaps it is not too much to assume, largely in different States from either. The intent of the combination is not merely to restrict competition among the parties, but, as we have said, by force of the general allegation at the end of the bill, to aid in an attempt to monopolize commerce among the States.[6] ”
    —Justice Oliver Holmes, majority opinion in Swift & Co. v. United States (1983)[2]

    Impact

    The ruling in Swift & Co. v. United States broadened the definition of interstate in the Commerce Clause to include chains of commercial activity that cross state lines. The meat sold by the Bix Six was part of a larger chain of meat production that began on farms and ranches and culminated in retail sales.[1] The case syllabus broke down the court's characterization of interstate commerce:

    “ Even if the separate elements of such a scheme are lawful, when they are bound together by a common intent as parts of an unlawful scheme to monopolize interstate commerce, the plan may make the parts unlawful.


    When cattle are sent for sale from a place in one State, with the expectation they will end their transit, after purchase, in another State, and when, in effect, they do so with only the interruption necessary to find a purchaser at the stockyards, and when this is a constantly recurring course, it constitutes interstate commerce, and the purchase of the cattle is an incident of such commerce.[3][6]

    		”

    The case expanded the federal government's regulatory purview and contributed to the passage of the Pure Food and Drug Act and the Meat Inspection Act in 1906.[1]

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 Oyez, "Swift and Company v. United States," accessed May 11, 2018
    2. ↑ 2.0 2.1 2.2 2.3 Legal Information Institute, "Swift and Company v. United States," accessed May 11, 2018
    3. ↑ 3.0 3.1 JUSTIA, "Swift & Co. v. United States," accessed May 11, 2018
    4. ↑ Wex Legal Dictionary, "Sherman Antitrust Act," accessed May 11, 2018
    5. ↑ Cases and Points of the Supreme Court of the United States. (1905). Harvard Law Library. Washington D.C.: Judd & Detweiler, Printers.
    6. ↑ 6.0 6.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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