Addyston Pipe and Steel Company v. United States

Addyston Pipe and Steel Company v. United States

Infobox SCOTUS case
Litigants=Addyston Pipe and Steel Co. v. U.S.
ArgueDateA=April 26
DecideDate=December 4
FullName=Addyston Pipe and Steel Company et al., Appts., v. United States
Holding=Upheld the rule of reason doctrine regarding U.S. antitrust laws.
JoinMajority=Fuller, Harlan, Gray, Brewer, Brown, Shiras, White, McKenna
LawsApplied=First, Fourteenth amendment, Commerce Clause

"Addyston Pipe and Steel Co. v. United States", 85 F. 271 (6th Cir. 1898), was an important case in which the United States Court of Appeals for the Sixth Circuit determined that U.S. antitrust laws, as set forth in the Sherman Antitrust Act, were to be governed by a rule of reason. The opinion was written by Chief Judge William Howard Taft (who later became President of the United States, and then Chief Justice of the United States Supreme Court). Taft's reasoning was eventually adopted by the Supreme Court as the proper interpretation of the Sherman Act.


The defendants were pipemakers who were operating in agreement, so that when municipalities offered projects available to the lowest bidder, all companies but the one designated would overbid, thus guaranteeing the success of the designated low bidder (although it was still possible for a company outside the group to win).


The defendants asserted that this was a reasonable restraint of trade, and that the Sherman Act could not have meant to prevent such restraints.

Opinion of the court

The Sixth Circuit noted that it would be impossible for the Sherman Act to prohibit every restraint of trade, for that would even encompass employment contracts which, by their nature, restrain the employee from working elsewhere during the time that they are being paid to work for the employer. Therefore, reasonable restraints were permitted, but this would only apply "if the restraint was ancillary" to the main purpose of the agreement. No conventional restraint of trade can be enforced unless:
# it is ancillary to the main purpose of the lawful contract; and
# it is necessary to protect enjoyment of legit fruits or to protect from dangers.If the primary purpose is to restrain trade, then the agreement is invalid, and in this case, the restraint was direct, and therefore invalid.

Later developments

This case was appealed to the Supreme Court as "Addyston Pipe and Steel Company v. United States", 175 U.S. 211 (1899) [ussc|175|211|Text of the opinion on appeal on] , but in that case the defendants did not attack the reasoning of the Sixth Circuit. Instead, they argued that there had been no interstate commerce (to which the Sherman Act was restricted). The Supreme Court disagreed, noting that there was interstate shipping of the pipes being sold.

ee also

*List of United States Supreme Court cases, volume 175


Wikimedia Foundation. 2010.

Look at other dictionaries:

  • Standard Oil Co. of New Jersey v. United States — SCOTUSCase Litigants=Standard Oil Co. of New Jersey v. United States ArgueDateA=March 14 ArgueDateB=16 ArgueYear=1910 ReargueDateA=January 12 ReargueDateB=17 ReargueYear=1911 DecideDate=May 15 DecideYear=1911 FullName=The Standard Oil Company of… …   Wikipedia

  • List of United States courts of appeals cases — Every year, each of the eleven United States courts of appeals decides hundreds of cases. Of those, a few are so important that they later become models for decisions of other circuits, and of the United States Supreme Court, while others are… …   Wikipedia

  • List of United States Supreme Court cases, volume 175 — This is a list of all the United States Supreme Court cases from volume 175:SCOTUSTable | data =SCOTUSRow case name = Ray Jones v. Patrick Meehan page = 1 decision date = decision year = 1899SCOTUSRow case name = John Scudder v. Bird S Coler page …   Wikipedia

  • Addyston — Addyston …   Deutsch Wikipedia

  • Mergers and acquisitions — Merger redirects here. For other uses, see Merge (disambiguation). For other uses of acquisition , see Acquisition (disambiguation). Accountancy Key concepts Accountant · Accounting period · Bookkeeping · Cash and accrual basis …   Wikipedia

  • Sherman Antitrust Act — Sen. John Sherman (R OH), the principal author of the Sherman Antitrust Act …   Wikipedia

  • John K. Richards — (March 15, 1856 March 1, 1909), jurist, son of Samuel and Sarah (Kelvey) Richards, was born in Ironton, Lawrence County, Ohio. Having received his early education in the schools of his native town, John Richards graduated from Swarthmore College… …   Wikipedia