Supreme Court Rules Against Beef Trust, Establishes Stream of Commerce Doctrine

On January 30, 1905, the U.S. Supreme Court ruled in Swift & Co. v. United States that the Commerce Clause allowed the federal government to regulate monopolies that have a direct effect on interstate commerce, dealing a major blow to the “Beef Trust” cartel. The case followed Attorney General Philander Knox’s 1902 lawsuit against Swift, Armour, Morris, Cudahy, Wilson, and Schwartzchild—six companies controlling half the national meat market with $700 million in annual revenues—for price-fixing, pooling agreements, and monopolistic practices. After federal injunctions were issued in May 1902, the companies merged into National Packing Company in 1903 to evade enforcement. The Supreme Court’s ruling established the “stream of commerce” doctrine, holding that even though livestock slaughter occurred locally, the monopolistic activities were part of an interstate commercial stream subject to federal regulation under the Sherman Antitrust Act. This decision significantly expanded federal antitrust enforcement power beyond direct interstate transactions to include activities with substantial effects on interstate commerce. The ruling marked Roosevelt’s second major trust-busting victory and demonstrated that antitrust enforcement could reach consumer-facing industries where monopolistic practices directly affected American families through inflated food prices. The stream of commerce doctrine would become a cornerstone of federal regulatory authority, enabling government oversight of industrial concentration across multiple sectors. However, the breakup of the Beef Trust proved incomplete—successor companies continued to wield substantial market power, revealing the limitations of antitrust enforcement in preventing reconsolidation of corporate control through new organizational structures.