Swift and Co. v. United States
"Swift and Co. v. United States" is a significant Supreme Court case that addresses the intersection of antitrust law and interstate commerce. The federal government accused several meatpacking companies, including Swift and Company, of engaging in price-fixing of livestock, which violated the Sherman Antitrust Act. The companies contended that their transactions were local in nature, arguing that they fell under the definition of intrastate commerce as the livestock were sold while "at rest." This claim relied on precedents like the case of United States v. E. C. Knight Co., which had previously limited the scope of interstate commerce.
However, the Supreme Court, led by Justice Oliver Wendell Holmes, defined commerce in a broader context, stating that the buying and selling of cattle were part of a larger interstate commerce flow. This ruling emphasized a practical view of commerce, suggesting that local transactions could combine to form a broader commercial activity spanning state lines. Although the decision did not broadly expand the definition of interstate commerce to all economic activities, it paved the way for future cases, such as United States v. Darby Lumber Co., which further explored these concepts. This case remains a pivotal moment in understanding the application of antitrust laws and the broader interpretation of commerce in the United States.
Swift and Co. v. United States
Date: January 30, 1905
Citation: 196 U.S. 375
Issues: Antitrust law; interstate commerce
Significance: Adopting the stream of commerce doctrine, the Supreme Court held that antitrust laws could be constitutionally applied to stockyard transactions.
The federal government charged several meatpackers, including Swift and Company, with fixing livestock prices at the stockyards, in violation of the Sherman Antitrust Act (1890). The companies argued that the buying and selling of livestock was an intrastate transaction, occurring while the cattle were “at rest.” For support, they pointed to United States v. E. C. Knight Co. (1895), which had narrowly defined the concept of interstate commerce.
Speaking for a unanimous Supreme Court, Justice Oliver Wendell Holmes held that the buying and selling of cattle was a part of a larger act of interstate commerce. Defining commerce as more of a practical than a technical, legal concept, Holmes ignored that the sales transactions took place in local jurisdictions. He wrote that these separate local transactions combined into “a current of commerce among the states.” At the time, the broad definition of commerce in the Swift decision was applied to very few economic activities because it did not overturn the Court’s earlier ruling that manufacturing was not a part of interstate commerce. The decision, however, helped lay a foundation for United States v. Darby Lumber Co. (1941).