Landmark Supreme Court Case: Swift & Company v. U.S. (1905)
Swift & Company v. U.S. (1905) is the 37th landmark Supreme Court case, the sixteenth in the Economics module, featured in the KTB Prep American Government and Civics Series designed to acquaint users with the origins, concepts, organizations, and policies of the United States government and political system. The goal is greater familiarization with the rights and obligations of citizenship at the local, state, national, and global levels and the history of our nation as a democracy. While there is overlap, these landmark cases are separated into cases addressing:
- Foreign Policy
- Public Safety
- Death Penalty
- Speech, Press, and Protest
- Criminal Justice
- Politics, Society, Freedom, and Equality
The Supreme Court
The Supreme Court is the highest court in the United States. Article III of the U.S. Constitution created the Supreme Court and authorized Congress to pass laws establishing a system of lower courts. The Constitution elaborated neither the exact powers and prerogatives of the Supreme Court nor the organization of the Judicial Branch as a whole. Thus, it has been left to Congress and to the Justices of the Court through their decisions to develop the Federal Judiciary and a body of Federal law.
The number of Justices on the Supreme Court changed six times before settling at the present total of nine in 1869. Since the formation of the Court in 1790, there have been only 17 Chief Justices* and 102 Associate Justices, with Justices serving for an average of 16 years. On average a new Justice joins the Court almost every two years.
The Supreme Court of the United States hears about 100 to 150 appeals of the more than 7,000 cases it is asked to review every year. That means the decisions made by the 12 Circuit Courts of Appeals across the country and the Federal Circuit Court are the last word in thousands of cases.
Court of Appeals
In the federal court system’s present form, 94 district level trial courts and 13 courts of appeals sit below the Supreme Court. The 94 federal judicial districts are organized into 12 regional circuits, each of which has a court of appeals. The appellate court’s task is to determine whether or not the law was applied correctly in the trial court. Appeals courts consist of three judges and do not use a jury.
The appellate courts do not retry cases or hear new evidence. They do not hear witnesses testify. There is no jury. Appellate courts review the procedures and the decisions in the trial court to make sure that the proceedings were fair and that the proper law was applied correctly.
A court of appeals hears challenges to district court decisions from courts located within its circuit, as well as appeals from decisions of federal administrative agencies. In addition, the Court of Appeals for the Federal Circuit has nationwide jurisdiction to hear appeals in specialized cases, such as those involving patent laws, and cases decided by the U.S. Court of International Trade and the U.S. Court of Federal Claims.
The nation’s 94 trial courts are called U.S. District Courts. At a trial in a U.S. District Court, witnesses give testimony and a judge or jury decides who is guilty or not guilty — or who is liable or not liable. District courts resolve disputes by determining the facts and applying legal principles to decide who is right.
Trial courts include the district judge who tries the case and a jury that decides the case. Magistrate judges assist district judges in preparing cases for trial. They may also conduct trials in misdemeanor cases.
There is at least one district court in each state, and the District of Columbia. Each district includes a U.S. bankruptcy court as a unit of the district court.
Federal courts have exclusive jurisdiction over bankruptcy cases involving personal, business, or farm bankruptcy. This means a bankruptcy case cannot be filed in state court. Bankruptcy Appellate Panels (BAPs) are 3-judge panels authorized to hear appeals of bankruptcy court decisions. These panels are a unit of the federal courts of appeals, and must be established by that circuit. Five circuits have established panels: First Circuit, Sixth Circuit, Eighth Circuit, Ninth Circuit, and Tenth Circuit.
Swift & Company v. U.S. (1905)
Swift & Company Facts:
A “beef trust” developed in Chicago, in which the “Big Six” leading meatpackers were engaged in a conspiracy to fix prices and divide the market for livestock and meat in their quest for higher prices and higher profits. They blacklisted competitors who failed to go along, used false bids, and accepted rebates from the railroads. Six companies: Swift, Armour, Morris, Cudahy, Wilson and Schwartzchild did $700 million a year in business and collectively controlled half of the national market, and up to 75% in New York City.
In 1902, President Theodore Roosevelt directed his attorney general to bring a lawsuit against the “beef trust” on antitrust grounds pursuant to the Sherman Antitrust Act of 1890. In 1903, The Big Six agreed to merge into one National Packing Company to continue to control the trade internally.
Q: Did Congress have the authority to regulate the meat trust under the Sherman Anti-Trust Act?
A: Yes. The Court held that congressional power under the Commerce Clause justified regulations of the “beef trust.”
Swift & Company Conclusion
Unanimous decision ruling the Commerce Clause allows the federal government to regulate monopolies if it has a direct effect on commerce. The Court established a “stream of commerce” (or “current of commerce”) argument that allows Congress to regulate things that fall into either category.
In particular it allowed Congress to regulate the Chicago slaughterhouse industry. Even though the slaughterhouse supposedly dealt with only intrastate matters, the butchering of meat was merely a “station” along the way between cow and meat. Thus, as it was part of the greater meat industry that was between the several states, Congress can regulate it.
The federal government’s victory in the case encouraged it to pursue other antitrust actions. Public opinion, outraged by Upton Sinclair’s novel The Jungle, which depicted horribly unsanitary conditions in Chicago’s meatpacking plants, supported the decision. Congress followed by passing in 1906 both the Pure Food and Drug Act and the Meat Inspection Act.
Next Economic Case: Muller v. Oregon (1908)
Previous Economic Case: Lochner v. New York (1905)