to such States were part of the
transaction.[427] Thus, sales of the type which in the Sugar Trust Case
were thrust to one side as immaterial from the point of view of the law,
because they enabled manufacture "to fulfill its function," were here
treated as merged in an interstate commerce stream. Thus, the concept of
commerce as _trade_, that is, as _traffic_, again entered the
Constitutional Law picture, with the result that conditions which
directly affected interstate trade could not be dismissed on the ground
that they affected interstate commerce, in the sense of interstate
_transportation_, only "indirectly." Lastly, the Court added these
significant words: "But we do not mean to imply that the rule which
marks the point at which State taxation or regulation becomes
permissible necessarily is beyond the scope of interference by Congress
in cases where such interference is deemed necessary for the protection
of commerce among the States."[428] That is to say, the line that
confines State power from one side does not always confine national
power from the other. For even though the line accurately divides the
subject matter of the complementary spheres, still national power is
always entitled to take on such additional extension as is requisite to
guarantee its effective exercise, and is furthermore supreme.
THE DANBURY HATTERS CASE
In this respect, the Swift Case only states what the Shreveport Case was
later to declare more explicitly; and the same may be said of an ensuing
series of cases in which combinations of employees engaged in such
intrastate activities as manufacturing, mining, building construction,
and the distribution of poultry were subjected to the penalties of the
Sherman Act because of the effect or intended effect of their activities
on interstate commerce.[429]
STOCKYARDS AND GRAIN FUTURES ACTS
In 1921 Congress passed the Packers and Stockyards Act[430] whereby the
business of commission men and livestock dealers in the chief stockyards
of the country was brought under national supervision; and the year
following it passed the Grain Futures Act[431] whereby exchanges dealing
in grain futures were subjected to control. The decisions of the Court
sustaining these measures both built directly upon the Swift Case.
In Stafford _v._ Wallace,[432] which involved the former act, Chief
Justice Taft, speaking for the Court, said: "The object to be secured by
the act is the free and unburden
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