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Maple Flooring Mfrs. Ass'n v. United States - 268 U.S. 563, 45 S. Ct. 578 (1925)

Rule:

Each case arising under the Sherman Act, 26 Stat. 209, must be determined upon the particular facts disclosed by the record. The opinions in those cases must be read in the light of their facts and of a clear recognition of the essential differences in the facts of those cases, and in the facts of any new case to which the rule of earlier decisions is to be applied.

Facts:

The United States was granted an injunction restraining Maple Flooring Manufacturers Association (“Maple Flooring”), a trade union, and its members from engaging in activities that allegedly violated the Sherman Act, 26 Stat. 209. Maple Flooring appealed.

Issue:

Did the district court err in awarding the injunction dissolving Maple Flooring and enjoining them from engaging in activities that allegedly violated the Sherman Act, 26 Stat. 209?

Answer:

Yes

Conclusion:

The Court reversed the decision finding that the activities in question, which included gathering and disseminating information as to the average cost of appellants' product, freight rates, and trade statistics, were legitimate subjects of enquiry and knowledge in any industry and did not have a necessary tendency to cause direct and undue restraint of competition in commerce. The Court concluded that where it was neither alleged nor proved that there was any agreement among Maple Flooring that affected production or fixed prices, Maple Flooring did not become conspirators engaged in restraint of interstate commerce merely because they shared trade information and made use of it in the management and control of their individual businesses.

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