Standard Oil v. United States

Lochner EraEconomic Regulation

The Court ordered the breakup of the Standard Oil monopoly and articulated the rule of reason for antitrust cases.

Overview

The government sued to dissolve John D. Rockefeller's Standard Oil trust, which controlled roughly ninety percent of American oil refining. Through Chief Justice White, the Court held that the Sherman Act barred only unreasonable restraints of trade, importing a common law rule of reason rather than condemning every restraint outright. Applying that standard, the Court found Standard Oil's systematic elimination of competitors unreasonable and ordered dissolution into dozens of separate companies. The rule of reason remains the governing framework of antitrust analysis, and the breakup ironically spawned successor companies that grew larger still.

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