Trans-Missouri Freight Case
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''United States v. Trans-Missouri Freight Association'', 166 U.S. 290 (1897), was a
United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that turn on question ...
case holding that the
Sherman Act The Sherman Antitrust Act of 1890 (, ) is a United States antitrust law which prescribes the rule of free competition among those engaged in commerce and consequently prohibits unfair monopolies. It was passed by Congress and is named for ...
(which was an
antitrust Competition law is the field of law that promotes or seeks to maintain market competition by regulating anti-competitive conduct by companies. Competition law is implemented through public and private enforcement. It is also known as antitrust l ...
measure that prohibited anticompetitive behavior in commerce) applied to the
railroad Rail transport (also known as train transport) is a means of transport using wheeled vehicles running in railway track, tracks, which usually consist of two parallel steel railway track, rails. Rail transport is one of the two primary means of ...
industry, even though the
U.S. Congress The United States Congress is the legislative branch of the federal government of the United States. It is a bicameral legislature, including a lower body, the U.S. House of Representatives, and an upper body, the U.S. Senate. They both ...
had enacted a comprehensive regime of regulations for that industry.


Background

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

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

* US antitrust law * List of United States Supreme Court cases, volume 166


References


External links

* * 1897 in United States case law United States antitrust case law United States Supreme Court cases United States Supreme Court cases of the Fuller Court Freight transport {{SCOTUS-Fuller-stub