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Standard Oil Co. v. United States - 221 U.S. 1, 31 S. Ct. 502 (1911)

Rule:

Every contract, combination in the form of trust or otherwise, or conspiracy in restraint of trade or commerce is declared to be illegal.

Facts:

Defendant oil companies sought review of an order from the Circuit Court of the United States for the Eastern District of Missouri, which held that the combining of defendants' stock constituted a restraint of trade and an attempt to monopolize the oil industry. Plaintiff United States filed an action alleging that defendants, an oil corporation and 37 other corporations, were engaged in conspiring to restrain the trade and commerce in petroleum and to monopolize the petroleum industry. The trial court awarded judgment to plaintiff, finding that the combining of defendants' stock constituted a restraint of trade and an attempt to monopolize.

In 1909, a federal court found Rockefeller's company, Standard Oil, in violation of the Sherman Antitrust Act. The court ordered the dissolution of the company.

Issue:

Did Standard Oil violate the Sherman Act?

Answer:

Yes.

Conclusion:

The Supreme Court affirmed, holding that plaintiff established prima facie intent and purpose on the part of defendants to maintain dominance over the oil industry, not as a result of normal methods of industrial development, but by new means of combination that were resorted to in order that greater power might be added than would otherwise have arisen had normal methods been followed. The Court found that defendants sought to exclude others from the trade and to control the movement of petroleum in the channels of interstate commerce.

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