United States v. Terminal Railroad Association
| United States v. Terminal Railroad Association | |
|---|---|
| Argued October 20–23, 1911 Decided April 22, 1912 | |
| Full case name | United States v. Terminal Railroad Association of St. Louis |
| Citations | 224 U.S. 383 (more) 32 S. Ct. 507; 56 L. Ed. 810 |
| Holding | |
| It is a violation of the antitrust laws to refuse to allow a competitor access to a facility necessary for entering or remaining in the market. | |
| Court membership | |
| |
| Case opinion | |
| Majority | Lurton, joined by unanimous |
| Holmes took no part in the consideration or decision of the case. | |
| Laws applied | |
| Sherman Antitrust Act, 15 U.S.C. §§ 1–2 | |
United States v. Terminal Railroad Association, 224 U.S. 383 (1912), is the first case in which the United States Supreme Court held it a violation of the antitrust laws to refuse to a competitor access to a facility necessary for entering or remaining in the market (an "essential facility"). In this case a combination of firms was carrying out the restrictive practice, rather than a single firm, which made the conduct susceptible to challenge under section 1 of the Sherman Act (15 U.S.C. § 1) rather than under the heightened standard of section 2 of that act (15 U.S.C. § 2). Even so, the case was brought under both sections.