## Facts

- The United States brought a civil Sherman Act enforcement suit in equity against American Can Company, a dominant national manufacturer of tin cans and related equipment.
- American Can was created in 1899 through consolidation of many competing can manufacturers and expanded by acquiring additional rivals.
- The government alleged American Can pursued a course of acquisitions and related practices intended to eliminate competition and secure control of the tin-can trade.
- Evidence showed American Can often purchased competitors for prices above the value of their assets, reinforcing pressures on remaining independents to sell.
- American Can’s associations with key tin-plate supply sources contributed to competitors’ fears of being denied essential raw materials.
- After consolidating much of the industry, American Can was able to raise prices, indicating market power and reduced competitive constraints.
- American Can argued its scale produced efficiencies and customer benefits, including standardization, improved quality, and economies of scale.

## Issues

1. Whether American Can’s formation, acquisitions, and related conduct constituted unlawful restraint of trade and/or monopolization or attempted monopolization under Sherman Act §§ 1–2.
2. If liability existed, whether equity required dissolution of the company or could impose narrower injunctive relief.

## Decision

- The district court held American Can violated the Sherman Act and found a monopoly existed in the tin-can industry.
- The court concluded the company was designed as a monopoly and achieved monopolistic power through consolidation and exclusionary conduct.
- The court declined to order dissolution, finding breakup too drastic under the circumstances.
- The court instead provided more limited equitable relief aimed at restraining unlawful practices rather than structurally separating the business.

## Legal Principles

- A firm may violate Sherman Act § 2 when monopoly power is acquired or maintained through exclusionary consolidation and conduct, including systematic absorption of rivals and control over essential inputs.
- Claimed efficiencies and customer benefits do not immunize monopolization when market power is achieved through anticompetitive combination or practices prohibited by the Sherman Act.
- In shaping antitrust remedies, a court of equity may reject dissolution where it finds structural relief disproportionate and may instead order tailored injunctive measures to prevent continued anticompetitive conduct.

## Conclusion

The court found that American Can unlawfully monopolized the tin-can industry under the Sherman Act but, exercising equitable discretion, refused to dissolve the company and opted for narrower injunctive relief to address the anticompetitive conduct.


United States v. American Can Co., 230 F. 859 (D. Md. 1916)