United States v. Brims

Background

Local manufacturers of millwork in Chicago, some building contractors, and union representatives were charged with agreeing to restrain trade by refusing to install millwork made by nonunion mills. The record shows out-of-state, nonunion mills—mostly in Wisconsin and the South—were undercutting Chicago makers by selling cheaper products, shrinking local manufacturers’ business and reducing union employment and wages.

Reasoning

The appeals court had overturned the criminal convictions, saying the written charge described stopping out-of-state mills from selling in Chicago but the proof showed only an agreement to refuse nonunion-made millwork wherever made. The Supreme Court disagreed. It found evidence that the agreement effectively reduced competition from out-of-state mills, increased local manufacturers’ output and prices, and directly and materially impeded interstate trade. For those reasons, the Court concluded the conviction should not have been reversed.

Real world impact

The decision sends the case back to the appeals court for further proceedings consistent with the Supreme Court’s view that an agreement to exclude nonunion-made goods can be treated as a restraint on interstate commerce. That means similar local agreements to shut out out-of-state competitors can be prosecuted as harming interstate trade, and affected sellers, buyers, workers, and the public may see changes in market access, employment, and prices.