Mitchel v Reynolds (1711) 1 PWms 181 is decision in the history of the law of restraint of trade, handed down in 1711. It is generally cited for establishing the principle that reasonable restraints of trade, unlike unreasonable restraints of trade, are permissible and therefore enforceable and not a basis for civil or criminal liability. It is largely the basis in US antitrust law for the "rule of reason."[1] William Howard Taft, then Chief Judge of the Sixth Circuit Court of Appeals, later US President and then Chief Justice of the Supreme Court, quoted Mitchel extensively when he first developed the antitrust rule-of-reason doctrine in Addyston Pipe & Steel Co. v. United States,[2] which was affirmed in 1899 by the Supreme Court.[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).[4]
Quick Facts Mitchel v Reynolds, Court ...
Mitchel v Reynolds |
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A bake shop |
Court | Court of the Queen's Bench |
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Citation(s) | (1711) 1 PWms 181, 24 ER 347, 45 Digest (Repl) 395, [1558-1774] All ER Rep 26 |
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Judge(s) sitting | Lord Macclesfield |
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Restraint of trade |
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Mitchel is also cited for the proposition that usually harmful practices may be rebuttably presumed unlawful, so that the burden of showing legitimacy is placed on the proponent of the practice.[5]