John D. Rockefeller · 1911 · Oyez / U.S. Supreme Court
Standard Oil Company of New Jersey v. United States, 221 U.S. 1 (1911)
In 1909 a federal circuit court found John D. Rockefeller's Standard Oil Company in violation of the Sherman Antitrust Act of 1890 and ordered its dissolution. Standard Oil appealed, and the case reached the U.S. Supreme Court as Standard Oil Company of New Jersey v. United States, argued across multiple days in March 1910 and January 1911. On May 15, 1911, the Court unanimously upheld the lower court's dissolution decree. Chief Justice Edward Douglass White's majority opinion introduced what became known as the 'rule of reason': the Sherman Act, the Court held, barred only those contracts and combinations that placed unreasonable restraints on trade, not every restraint in any form. Standard Oil lost the case, but the rule-of-reason standard narrowed the Sherman Act's reach considerably, and for the next two decades it shaped how federal courts evaluated industrial combinations. The decree is the founding precedent of modern American antitrust law.