United States v. E.C. Knight Co.

Wed, 24 Oct 1894 13:00:00 +0000

Location

Congress

Constitution and Delaware Street Washington D.C. 20002

Washington 20002

United States

38° 53' 31.1496" N, 77° 0' 29.1744" W

See map: Google Maps

Case Basics

Docket No.

675

Petitioner

United States

Petitioner Type

Petitioner

Respondent

E.C. Knight Co.

Respondent Type

Respondent

Heard By

Fuller Court (1894-1895)

Decided By

Fuller Court (1894-1895)

Opinion

156 U.S. 1 (1895)

Argued

Wednesday, October 24, 1894

Decided

Monday, January 21, 1895

Facts of the Case

The Congress passed the Sherman Anti-Trust Act in 1890 as a response to the public concern in the growth of giant combinations controlling tranportation, industry, and commerce. The Act aimed to stop the concentration of wealth and economic power in the hands of the few. It outlawed "every contract, combination...or conspiracy, in restraint of trade" or interstate commerce, and it declared every attempt to monopolize any part of trade or commerce to be illegal. The E.C. Knight Company was such a combination controlling over 98 percent of the sugar-refining business in the United States.

Question

Did Congress exceed its constitutional authority under the Commerce Clause when it enacted the Sherman Anti-Trust Act?

Conclusion

Decision: 8 votes for E. C. Knight Co., 1 vote(s) against
Legal provision: Sherman Antitrust Act; US Const. Art 1, Section 8

The Act was constitutional but it did not apply to manufacturing. Manufacturing was not commerce, declared Fuller for the majority; the law did not reach the admitted monopolization of manufacturing (in this case, refining sugar). Although American Sugar had monopolized manufacturing, the Court found no violation of the Sherman Act because the acquisition of the Philadelphia refineries involved intrastate commerce. The trust did not lead to control of interstate commerce and so "affects it only incidentally and indirectly."

Pollock v. Farmers' Loan & Trust Co.

Thu, 07 Mar 1895 13:00:00 +0000

Location

Congress

Constitution and Delaware Street Washington D.C. 20002

Washington 20002

United States

38° 53' 31.1496" N, 77° 0' 29.1744" W

See map: Google Maps

Case Basics

Docket No.

893

Petitioner

Pollock

Petitioner Type

Petitioner

Respondent

Farmers' Loan & Trust Co.

Respondent Type

Respondent

Heard By

Fuller Court (1894-1895)

Decided By

Fuller Court (1894-1895)

Opinion

157 U.S. 429 (1895)

Argued

Thursday, March 7, 1895

Decided

Monday, May 20, 1895

Facts of the Case

The Constitution gave the states the power to impose direct taxation. The federal government could impose direct taxes as well, but only if those taxes were apportioned among the states in proportion to their representation in Congress. In this case the Court examined a national income tax passed by Congress in 1894. This case was decided together with Hyde v. Continental Trust Company of the City of New York.

Question

Was the income tax a direct tax in violation of the Constitution (Article I, Section 9)?

Conclusion

Yes. The Court held that the act violated the Constitution since it imposed taxes on personal income derived from real estate investments and personal property such as stocks and bonds; this was a direct taxation scheme, not apportioned properly among the states. The decision was negated by the adoption of the Sixteenth Amendment in 1913.

Cases - 1894 term

United States v. E.C. Knight Co.

Location

Pollock v. Farmers' Loan & Trust Co.

Location