United States v. Columbia Steel Co.
United States Supreme Court
334 U.S. 495 (1948)
U.S. Steel Corporation (US Steel) (defendant), a major rolled-steel supplier, agreed to acquire Consolidated Steel Corporation (CSC), a steel fabricator that had accounted for only about 3% of national rolled-steel demand over the prior decade and had previously bought its rolled steel competitively from US Steel and other manufacturers. The United States (plaintiff) sued to enjoin the merger, arguing it would let US Steel become CSC's exclusive rolled-steel supplier and unreasonably restrain competition in that market. The district court ruled for US Steel, and the government appealed.
Whether a merger that creates vertical integration and an exclusive-dealing arrangement between the merged companies is automatically ('per se') illegal under the Sherman Act.