United States v. Goldman

Background

The United States sued to enforce the Sherman Antitrust Act and obtained an injunction. Jacob A. Goldman and others were later charged with criminal contempt for violating that injunction. The defendants moved to dismiss the information, arguing that Section 25 of the Clayton Act imposed a one-year limit for contempt proceedings. The district court agreed and dismissed the charges. The United States appealed directly to this Court under the Criminal Appeals Act. Before trial an examiner took testimony, and the defendants had not been placed in jeopardy when the dismissal occurred.

Reasoning

The Court first held it had jurisdiction because prosecutions for criminal contempt are “criminal cases” under the Criminal Appeals Act. The main legal question was whether the Clayton Act’s one-year limit applied. Reading Sections 21–25 together, the Court concluded the Act was narrowly aimed at certain contempts and that Section 24 specifically excepted contempts arising from disobedience of decrees entered in suits brought in the name of the United States. Because of that exception, Section 25’s one-year limitation did not apply to prosecutions for violating a decree in a suit prosecuted by the United States. The Court therefore reversed the district court’s dismissal.

Real world impact

The ruling allows the federal government to pursue criminal contempt prosecutions for violations of court decrees entered in government-initiated suits even when the alleged acts occurred more than a year earlier. Individuals and companies who disobey federal injunctions in cases brought by the United States may face prosecution despite the one-year clause of Section 25. This decision clarifies how the Clayton Act limits apply to government enforcement actions.