Sherman Anti-Trust and E. C. Knight Co.

One of the first collisions with the Sherman Anti-Trust Act deals with the E.C. Knight Company. The E.C. Knight Company was a trust owned by American Sugar. Eventually, American Sugar monopolized almost 98% of the country's sugar. The case makes its way to the Supreme Court in 1894. The question the Justices need to decipher is if the Constitution oversteps the Commerce Clause or Article 1 Section 8 of the Constitution.

As previously stated, Article 1 Section 8 of the Constitution is intended, “To regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes.”⁵ Now what the court dealt with is the open-ended verbiage in the Sherman Anti-Trust Act. The Justices focus on the word manufacture. The reason they zone in on manufacturing is to make an understanding of what is ""mercantile" in nature, which Congress could regulate, and those "industrial" in nature, which the Court ruled Congress could not regulate.”⁶ The court decided that manufacturing is under the word industrial, which would not fall under Article 1 section 8 of the Constitution. Most importantly though, the manufacturing of the sugar occurred in one state only. The case is ruled by an eight-to-one decision in favor of the E.C. Knight Company.

Shortly after the decision is made many people are upset about the different interpretations of the Sherman Anti-Trust Act. The New York Tribune voices the people's opinion saying, “The restricted scope of the provisions of this law, as they have been constructed by the courts, especially in the case of United States against E.C. Knight Company (156 U.S. 1), makes amendments necessary if any effective action is expected from this department.”⁷

^Footnotes

^{5 National Archives. “The Constitution of the United States: A Transcription.” National Archives and Records Administration. National Archives and Records Administration. Accessed April 17, 2023. https://www.archives.gov/founding-docs/constitution-transcript?_ga=2.49811110.1604126544.1681316291-1064336171.1680968933.}

^{6 McBride, Alex. “The Supreme Court . Capitalism and Conflict . Landmark Cases . United States v. E. C. Knight (1895): PBS.” The Supreme Court . Capitalism and Conflict . Landmark Cases . United States v. E. C. Knight (1895) | PBS, December 2006. https://www.thirteen.org/wnet/supremecourt/capitalism/landmark_knight.html.}

^{7 Levy, Felin H. “MR. ROOSEVELT AND THE SUPREME COURT: A Citation of Views Concerning Knight Case Decision.” New - York Tribune (1900-1910). September 9, 1910.}