Addyston Pipe and Steel Co. v. United States

175 U.S. 211 (1899)

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Addyston Pipe and Steel Co. v. United States

United States Supreme Court
175 U.S. 211 (1899)

Facts

The federal government (defendant) filed suit against a group of pipemakers, including Addyston Pipe and Steel Company (plaintiffs), operating under a concerted agreement. When a project for pipes was offered to the lowest bidder, all of the companies involved except the designated one would overbid the project, essentially enforcing a monopoly for the lowest bidder on each project. The government alleged violation of the Sherman Act, § 1, whereas the pipemakers argued that these actions were a reasonable restraint of trade and that the pipemakers were merely making a commodity that might be later sold out of state but were not directly impacting interstate commerce. This was an attempt to draw a parallel to a recent case in which the court had declined to involve itself with a monopoly of sugar manufacturing on the basis that such manufacture was not directly regarding the future disposition of the article and, thus, not directly involving interstate commerce. In this case, at the trial court level, the court ruled for the pipemakers, and the government appealed. The court of appeals ultimately found in favor of the government, but the pipemakers then appealed to the Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Peckham, J.)

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