Until a competing radio station appeared on the scene in 1948, defendant newspaper was the only medium for mass advertising available in the Lorain, Ohio area. In an effort to regain its monopoly position and eliminate the radio station as a competitor, defendant inaugurated a policy of refusing to accept custom from advertisers who employed the services of its rival. Both the newspaper and the radio station received news dispatches, advertising copy, payments, and other materials from sources outside Ohio, but neither had any appreciable audience beyond the borders of the state. In a civil action brought by the United States under sections 1 and 2 of the Sherman Act, the district court enjoined defendant from continuing its attempted monopolization. On appeal to the Supreme Court, held, affirmed. Defendant's activities came within the scope of the federal commerce power. Furthermore, the First Amendment gives newspapers no immunity from injunction under the anti-trust laws. Lorain Journal Co. v. United States, 342 U. S. 143, 72 S.Ct. 181 (1951).
William K. Davenport,
CONSTITUTIONAL LAW-COMMERCE CLAUSE-FREEDOM OF PRESS-AMENABILITY OF NEWSPAPER TO SHERMAN ANTI-TRUST ACT,
Mich. L. Rev.
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