Mitchel v Reynolds (1711) 1 PWms 181 is decision in the history of the law of restraint of trade, handed down in 1711 in England.
[3] The doctrine also played a major role in the 1911 Supreme Court case Standard Oil Company of New Jersey v. United States 221 U.S. 1 (1911).
[6] It was ancillary to a legitimate transaction (the rental or sale of the bakeshop business) and it was reasonably necessary to effectuate the main purpose.
[8] Lord Macclesfield was later impeached for corruption: involved in bribery to sell offices, and using client money (which he then lost) to speculate in the slave-trading South Sea Company.
[11]In the same vein, the U.S. Department of Justice and the Federal Trade Commission stated a similar approach in the 1995 Antitrust Guidelines for the Licensing of Intellectual Property: If the Agencies conclude that the restraint has, or is likely to have, an anticompetitive effect, they will consider whether it is reasonably necessary to achieve procompetitive efficiencies.
In one recent case, a court rejected a credit card issuer's attempted justification of a restriction against competitive dealings said to be reasonably necessary to promote "loyalty" and "cohesion.