confronted with the contention that the act had been intended only for
the industrial combinations, and hence was not designed to apply to the
railroads, for whose governance the Interstate Commerce Act had been
enacted three years prior. Justice Peckham answered the argument by
saying that "to exclude agreements as to rates by competing railroads *
* * would leave [very] little for the act to take effect upon,"
referring in this connection to the decision in the Sugar Trust Case,
166 U.S. at 313.

Alluding in his opinion for the Court in Mandeville Island Farms _v._
American C.S. Co., 334 U.S. 219 (1948) to the Sugar Trust Case, Justice
Rutledge said: "Like this one, that case involved the refining and
interstate distribution of sugar. But because the refining was done
wholly within a single state, the case was held to be one involving
'primarily' only 'production' or 'manufacturing,' although the vast part
of the sugar produced was sold and shipped interstate, and this was the
main end of the enterprise. The interstate distributing phase, however,
was regarded as being only 'incidentally,' 'indirectly,' or 'remotely'
involved; and to be 'incidental,' 'indirect,' or 'remote' was to be,
under the prevailing climate, beyond Congress' power to regulate, and
hence outside the scope of the Sherman Act. _See_ Wickard _v._ Filburn,
317 U.S. at 119 et seq. (1942).

"The _Knight_ decision made the statute a dead letter for more than a
decade and, had its full force remained unmodified, the Act today would
be a weak instrument, as would also the power of Congress, to reach
evils in all the vast operations of our gigantic national industrial
system antecedent to interstate sale and transportation of manufactured
products. Indeed, it and succeeding decisions, embracing the same
artificially drawn lines, produced a series of consequences for the
exercise of national power over industry conducted on a national scale
which the evolving nature of our industrialism foredoomed to reversal."
Ibid. 229-230.

[425] Swift & Co. _v._ United States, 196 U.S. 375, 396 (1905).

[426] 196 U.S. at 398-399.

[427] Ibid. 399-401.

[428] Ibid. 400.

[429] Loewe _v._ Lawlor, 208 U.S. 274 (1908); Duplex Printing Press Co.
_v._ Deering, 254 U.S. 443 (1921); Coronado Coal Co. _v._ United Mine
Workers of America, 268 U.S. 295 (1925); United States _v._ Brime, 272
U.S. 549 (1926); Bedford Co. _v._ Stone Cutters Assn., 274 U.S. 37
(1927); Local 16