The first case, to reach the Supreme Court was the so-called Sugar Trust Case of United States v. E. C. Knight Co.30

In this case it was contended by the Government that the acquisition by the American Sugar Refining Company of the stock of a number of sugar refining corporations of Pennsylvania was with the object and effect of establishing a substantial monopoly of the industry, and that inasmuch as the product was sold throughout the country and distributed among the States, the provision of the act of 1890 with reference to the monopolization or combination or conspiracy to monopolize trade and commerce among the States was violated. The court, however, applying the doctrine of Coe v. Errol31 and Kidd v. Pearson,32 held that the act did not, and constitutionally could not, extend to combinations, conspiracies or monopolies relating to the manufacture of commodities, this being a field reserved exclusively to the States. The fact that interstate or foreign trade might be incidentally affected was declared not material.33

The doctrine thus laid down by the court has never been departed from, and is, indeed, one from which there would seem to be no logical escape, if the line which divides federal control of interstate commerce from state regulation of local industries and manufacturing is to be maintained. In applying this doctrine, however, the court, in later cases, has shown a somewhat greater readiness to find in the acts complained of, a direct interference with interstate commerce, and, therefore, a ground for the application of the federal statute.

30 156 U. S. 1; 15 Sup. Ct. Rep. 249; 39 L. ed. 325.

31 16 U. S. 517; 6 Sup. Ct. Rep. 475; 29 L. ed. 275.

32 128 U. S. 1; 9 Sup. Ct. Rep. 6; 32 L. ed. 346.

33 "The object [of the combination] was manifestly private gain in the manufacture of the commodity, but not through the control of interstate or foreign commerce. It is true that the bill alleged that the products of these refineries were sold and distributed among the several States, and that all the companies were engaged in trade or commerce with the several States and with foreign nations; but this was not more than to say that trade or commerce served manufacture to fulfil its function. ... It does not follow that an attempt to monopolize, or the actual monopoly of, the manufacture was an attempt, whether executory or consummated, to monopolize commerce, even though, in order to dispose of the product. the instrumentality of commence was necessarily invoked. . . . That trade or commerce might be indirectly affected was not enough to entitle complainants to a decree."