United States v. Trans-Missouri Freight Association

Eighteen railroad companies operating west of the Mississippi formed the Trans-Missouri Freight Association (TMFA) (defendant) to set uniform freight rates and schedules for its members, eliminating price competition among them. The government (plaintiff) sued, alleging the arrangement violated the Sherman Act. The railroads argued their fixed rates were reasonable and, since such arrangements were valid at common law, the Sherman Act shouldn't reach them either. The district court and court of appeals agreed with the railroads, and the Supreme Court granted certiorari on whether a restraint of trade must be unreasonable to violate the Act.