# United States v. E. C. Knight Co. (1895) **Decided:** January 21, 1895 · Chief Justice Melville Fuller · 8–1 (Harlan dissenting) The first Supreme Court test of the [[Sherman Antitrust Act]], and a near-total defeat for it. The American Sugar Refining Company had acquired four Philadelphia refiners in 1892, reaching roughly **98% of national refining capacity**. The Court held that manufacturing is a *local* activity that affects interstate commerce only "incidentally and indirectly," and therefore lies outside the commerce power the Sherman Act was grounded in. The practical effect was to exempt manufacturing trusts — the ones the public was actually angry about — from the statute written to reach them, for roughly a decade. Harlan's lone dissent argued the majority had left the country defenseless against combinations organized on a national scale. The holding was worked around rather than overruled: *Addyston Pipe* (1899) reached a cartel because it fixed prices on goods shipped across state lines, and [[Northern Securities]] (1904) reached a holding company. The Commerce Clause reasoning did not fully die until the New Deal cases. > Stub — fill out. See [[US Antitrust and Monopoly Timeline]].