In United States v. E.C. Knight Co., the Supreme Court finds that the Sherman Antitrust Act of 1890, which protects against the establishment of corporate monopolies, is not applicable to manufacturing operations and is strictly limited to a narrow definition of commerce under the commerce clause. E.C. Knight Co. dominated the national sugar refining business with the purchase of four Philadelphia refineries. It was sued by the United States to cancel the agreement and maintain the autonomy of the different companies. The Court’s decision to permit the agreement is initially an obstacle to the legislative efforts of the New Deal, but is effectively reversed in 1937 in NLRB v. Jones & Laughlin Corp., making way for comprehensive legislation to combat the economic tumult of the Great Depression.