United States v. Trans-Missouri Freight Association

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1897 United States Supreme Court case

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.

Background

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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

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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. 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

See also

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• US antitrust law

• List of United States Supreme Court cases, volume 166

References

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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 (2003). "The Trans-Missouri Case: Does the Sherman Act Apply to Railroads?" . Essays in Economic & Business History. 21: 132–133.

External links

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• Works related to United States v. Trans-Missouri Freight Association at Wikisource
• Text of United States v. Trans-Missouri Freight Association, 166 U.S. 290 (1897) is available from: Justia Library of Congress

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United States antitrust law

• History

• Interstate Commerce Commission (1887–1996)

• Bureau of Corporations (1903–1915)

• Pujo Committee (1912–1913)

• Federal Trade Commission (1914–)

• U.S. Justice Department Antitrust Division (1919–)

• U.S. Senate Judiciary Antitrust Subcommittee

• U.S. House Judiciary Antitrust Subcommittee

Statutes and
regulations

• Interstate Commerce Act of 1887

• Sherman Antitrust Act (1890)

• Elkins Act (1903)

• Expediting Act (1903)

• Publicity In Taking Evidence Act (1913)

• Clayton Antitrust Act of 1914

• Federal Trade Commission Act of 1914

• Webb–Pomerene Act (1918)

• Willis Graham Act (1921)

• Capper–Volstead Act (1922)

• Robinson–Patman Act (1936)

• Wheeler–Lea Act (1938)

• McCarran–Ferguson Act (1945)

• Celler–Kefauver Act (1950)

• Sports Broadcasting Act of 1961

• Newspaper Preservation Act of 1970

• Tunney Act (1974)

• Hart–Scott–Rodino Antitrust Improvements Act (1976)

• National Cooperative Research and Production Act (1993)

• Executive Order 14036 (2021)

Supreme Court
case law

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• _Robertson v. National Basketball Ass'n _ (1977)
• _SmithKline Corp. v. Eli Lilly & Co. _ (1978)
• _United States v. Westinghouse Electric Co. _ (1981)
• _United States v. AT&T _ (1982)
• _Mid-South Grizzlies v. National Football League _ (1983)
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