United States v. E. C. Knight Co., 156 U.S. 1 (1895), also known as the "Sugar Trust Case," was a United States Supreme Court antitrust case that severely limited the federal government's power to pursue antitrust actions under the Sherman Antitrust Act. In Chief Justice Melville Fuller's majority opinion, the Court held that the U.S. Congress could not regulate manufacturing and thus gave state governments the sole power to take legal action against manufacturing monopolies. The case was the Supreme Court's first interpretation of the Sherman Antitrust Act. The case has never been overruled, but in Swift & Co. v. United States and subsequent cases, the Court has held that Congress can regulate manufacturing when it affects interstate commerce.
The case
In 1892, the American Sugar Refining Company gained control of the E. C. Knight Company and several others, which resulted in a 98% monopoly of the American sugar refining industry.
The decision
thumb|alt=The [[Fuller Court.|The Fuller Court.]]
The court's 8–1 decision, handed down on January 21, 1895 and written by Chief Justice Melville Weston Fuller, went against the government. Justice John Marshall Harlan dissented.
The Court held "that the result of the transaction was the creation of a monopoly in the manufacture of a necessary of life"
In his dissent, Harlan argued "the doctrine of the autonomy of the states cannot properly be invoked to justify a denial of power in the national government to meet such an emergency." He continued to argue the Constitution gives Congress "authority to enact all laws necessary and proper" to regulate commerce and cited McCulloch v. Maryland.