## Facts

- The United States sued under § 4 of the Sherman Act to enjoin U.S. Steel from purchasing all assets of Consolidated Steel Corporation, a major independent steel fabricator on the West Coast.
- The steel industry involved (1) rolled steel products (unfinished steel) and (2) fabricated steel products, including structural fabrication (e.g., bridges, building framework) and plate fabrication (e.g., pressure vessels, welded pipe).
- U.S. Steel was an integrated producer of rolled steel and also participated in fabrication through subsidiaries, including National Tube in pipe.
- Consolidated purchased rolled steel from multiple producers and fabricated it into structural steel, plate products, and pipe.
- The government alleged the acquisition would (1) foreclose other rolled-steel producers from selling to Consolidated because Consolidated would source rolled steel only from U.S. Steel, and (2) eliminate existing competition between Consolidated and U.S. Steel affiliates in structural fabrication and pipe.
- The government also argued that, combined with prior acquisitions (including a government-owned plant at Geneva, Utah), the deal showed an effort to monopolize fabricated steel products in the relevant area.
- The district court entered judgment for defendants after a bench trial; the government appealed directly to the Supreme Court.

## Issues

1. Whether the acquisition would constitute an unreasonable restraint of trade under Sherman Act § 1 by foreclosing rival rolled-steel producers from Consolidated’s demand and eliminating competition in fabricated products (structural and pipe).
2. Whether the acquisition, viewed with U.S. Steel’s prior acquisitions and position, amounted to an attempt to monopolize fabricated steel products in violation of Sherman Act § 2.
3. Whether the Sherman Act reaches restraints affecting a regional market, and if so, how the relevant geographic market bears on the § 1 and § 2 analyses.

## Decision

- The Supreme Court affirmed the judgment for defendants and refused to enjoin the acquisition.
- The Court held the Sherman Act is not limited to restraints with nationwide effects; it can reach unreasonable restraints within a regional competitive market.
- The Court concluded foreclosure of Consolidated as a purchaser of rolled steel did not unreasonably restrict other producers’ opportunities, emphasizing Consolidated’s relatively small share of rolled-steel demand and the availability of other outlets.
- The Court found the record did not prove that eliminating competition between Consolidated and U.S. Steel subsidiaries in structural fabrication or pipe constituted an unreasonable restraint, given the limited extent of their pre-acquisition rivalry and the presence of other competitors.
- The Court rejected § 2 liability, concluding the acquisition did not show specific intent to monopolize and reflected a normal business purpose, even when considered alongside prior acquisitions.

## Legal Principles

- The Sherman Act may be applied to unreasonable restraints in a regional market; nationwide impact is not required.
- Under § 1, a merger’s foreclosure or elimination of competition must be shown to be unreasonable in light of its magnitude and competitive effects; small or limited foreclosure may be insufficient.
- Under § 2, an attempt to monopolize requires proof of specific intent and a showing that the challenged conduct meaningfully advances monopolization; prior acquisitions may be relevant but do not alone establish unlawful intent.
- Elimination of rivalry between merging firms is not automatically unlawful; the plaintiff must prove the loss of competition is substantial enough to amount to an unreasonable restraint.

## Conclusion

The Court affirmed denial of injunctive relief because the government failed to prove that U.S. Steel’s acquisition of Consolidated would unreasonably restrain trade or constitute an attempt to monopolize; the alleged foreclosure and competitive overlap were too limited on the record to establish Sherman Act §§ 1 or 2 violations, even though the Act may address restraints within a regional market.


United States v. Columbia Steel Co., 334 U.S. 495 (1948)