Standard Oil Co. of New Jersey v. United States
221 U.S. 1 (1911), dissolved 34 companies controlled by John D. Rockefeller's Standard Oil Trust as constituting a monopoly in violation of the Sherman Antitrust Act. While in one sense the case was the high point of the “trust-busting” efforts of two presidents (see also Northern Securities Co. v. United States), in another sense it marked a turn toward a more conservative interpretation of the Sherman Act. Chief Justice Edward Douglass White promulgated the idea that a restraint of trade by a monopolistic business must be “unreasonable” to be illegal under the Sherman Act. White's failure, however, to define a “reasonable” restraint, coupled with the imprecise brevity of the Sherman Act, made subsequent antitrust decisions exceedingly difficult to predict.
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