U.S. President Grover Cleveland, in his second term of office (1893–1897), directed the national government to sue the Knight Company under the provisions of the Sherman Antitrust Act to prevent the acquisition.

The Court held "that the result of the transaction was the creation of a monopoly in the manufacture of a necessary of life"[1] but ruled that it "could not be suppressed under the provisions of the act.

[citation needed] In his dissent, Harlan argued "the doctrine of the autonomy of the states cannot properly be invoked to justify a denial of power in the national government to meet such an emergency."

He continued to argue the Constitution gives Congress "authority to enact all laws necessary and proper" to regulate commerce and cited McCulloch v. Maryland.

[1] Although the decision was never expressly overturned, the Court later retreated from its position in a series of cases such as Swift and Company v. United States, which have defined various steps of the manufacturing process as part of commerce.