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United States v. Columbia Steel Co.

United States Supreme Court
334 U.S. 495 (1948)


Facts

United States Steel Corporation (US Steel) (defendant) was a major player in the market for steel products. Through its subsidiaries, US Steel provided rolled-steel products to metal-working companies for fabrication into various structural and plate configurations. US Steel entered into an agreement to acquire Consolidated Steel Corporation (CSC), a company in the business of fabricating steel products. Prior to the merger, US Steel competed with other manufacturers of rolled steel to provide CSC with the steel material needed to fabricate CSC’s products. For the past 10 years, CSC had accounted for roughly 3 percent of the national demand for rolled steel. The United States (plaintiff) brought a complaint against US Steel, alleging that the prospective merger would violate the Sherman Act by preventing all rolled-steel manufacturers except US Steel from selling to CSC. The government sought an injunction to enjoin the merger, claiming that the merger would unreasonably restrain competition in the market for rolled steel. The district court ruled in favor of US Steel, and the government appealed the decision.

Rule of Law

Issue

Holding and Reasoning (Reed, J.)

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