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ANTI-BALLISTIC-MISSILE TREATY OF 1972 The Anti-Ballistic-Missile Treaty of 1972 ABM Treaty limited the number of defensive anti-ballistic missile ABM systems that the United States and t

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more debasing because they do not realize it.” She urged women to recognize the inequities they faced and to speak and act for their own freedom

When Anthony died in 1906, women did not yet have the right to vote in presidential elections

When the NINETEENTH AMENDMENT to the U.S

Constitution finally became law in 1920, it was called the Anthony amendment in recognition of her valiant efforts to gain suffrage

Anthony was also honored in 1979 and

1980, when the U.S Mint issued one dollar coins bearing her likeness She became the first woman to be pictured on a U.S coin in general circulation

FURTHER READINGS Barry, Kathleen 1988 Susan B Anthony: A Biography of a Singular Feminist New York: New York Univ Press.

Cooper, Ilene 1984 Susan B Anthony New York: Watts.

Gurko, Miriam 1974 The Ladies of Seneca Falls: The Birth of the Woman’s Rights Movement New York: Macmillan.

Wells, Ida B 1970 Crusade for Justice: The Autobiography of Ida B Wells Ed Alfreda M Duster Chicago: Univ of Chicago Press.

CROSS REFERENCES Fifteenth Amendment; Nineteenth Amendment; Stanton, Elizabeth Cady; Temperance Movement; Women ’s Rights.

ANTI-BALLISTIC-MISSILE TREATY

OF 1972 The Anti-Ballistic-Missile Treaty of 1972 (ABM Treaty) limited the number of defensive anti-ballistic missile (ABM) systems that the United States and the former Soviet Union could use in preparation for nuclear war (23 UST 3435: TIAS 7503; 944 UNTS 13, U.S DEPARTMENT OF STATE, Treaties in Force, 1993) Restrictions on ballistic missile defenses (BMDs), military warning systems designed to alert and protect a nation, composed the bulk of the treaty’s articles The treaty limited each country’s supply of remote-controlled, long-range nuclear rockets, or intercontinental ballistic missiles (ICBMs) Fol-lowing the breakup of the Soviet Union in 1991, the Russian Federation continued to adhere to the agreement In 2001, however, the United States announced that it would no longer abide

by the pact

On May 26, 1972, at the U.S.-Soviet summit

in Moscow, President RICHARD M NIXON of the United States and President Leonid Brezhnev of the Soviet Union signed, in conjunction with the Strategic Arms Limitation Talks of 1969–72 (SALT I), the ABM Treaty The treaty limited

each party to two ABM sites, with no more than one hundred ABM launchers and interceptors

at each site One of these sites could protect an ICBM silo deployment area, and the second could protect the national capital The treaty prohibited the development, testing, or deploy-ment of sea-based, air-based, space-based, or mobile land-based ABM systems Furthermore,

it excluded the transfer or deployment of ABM systems to or in other nations The 15 articles of the treaty were of unlimited duration and would come up for renewal every five years

The principles of the treaty explicitly reflected the policy of mutual assured destruc-tion (MAD)—the belief that the best way to control nuclear arms is to allow both sides enough power to ensure the destruction of both nations in the event of war As stated in Article I

of the treaty, each side agreed “not to deploy ABM systems for a defense of the territory of its country and not to provide a base for such a defense, and not to deploy ABM systems for defense of an individual region” (Durch 1988) Article II defines an ABM system as“a system to counter strategic ballistic missiles or their elements in flight trajectory, currently consist-ing of ABM interceptor missiles ABM launchers [and] ABM radars.” Article III reiterates the ban on ABM deployment, except-ing, for each side, one deployment area around the national capital and one around an ICBM launcher deployment area This provision was later reduced, in 1974, to just one deployment area for each country, allowing“no more than

100 ABM interceptor missiles at launch sites.” Articles IV to XV outline provisions for, among other issues, nuclear testing, radar deployment, amendments to the treaty, and the terms of treaty withdrawal

After the ABM Treaty was ratified by the U.S Congress, legislators refused to authorize funds for building an ABM site outside Washington, D.C In early 1975, the United States deployed its single permitted system near the Minuteman Fields at Grand Forks Air Force Base in North Dakota Within a year, however, Congress deactivated the system on the ground that it was not very cost-effective The Soviets, mean-while, used their ABM deployments to protect Moscow

Despite attempts to follow the principles of SALT I, continued limitations on strategic arms fell apart with the SALT II Treaty of 1979 The

308 ANTI-BALLISTIC-MISSILE TREATY OF 1972

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U.S Congress refused to ratify the treaty, which

had been signed by PresidentsJIMMY CARTERand

Leonid Brezhnev SALT II went on to draw

heavy fire in the 1980s from the newly

empowered Reagan administration Whereas

the Soviets generally adhered to a strict

interpretation of the ABM Treaty, President

RONALD REAGAN advocated “peace through

strength” and pushed for new WEAPONS

pro-grams and policies Reagan reinterpreted the

treaty liberally, putting it to its most serious test

His proposal to render nuclear ballistic missiles

ineffective and obsolete, with the Strategic

Defense Initiative (SDI), a space-based BMD

system popularly known as Star Wars, caused

great debate at home and considerable alarm in

the Soviet Union

Like Reagan, opponents of the ABM Treaty

believed that its limits were based on one-way

accommodation, that is, allowing the Soviets to

retain their numerical superiority, as seen in

SALT II The Soviets had previously established

numerical superiority in ICBM deployment,

and the ABM Treaty supposedly held back

the development of further U.S weapons

technology Especially troublesome to some was the Soviet’s Krasnoyarsk radar system in western Siberia According to Article VI of the ABM Treaty, an early-warning radar with this orienta-tion should have been located on the Pacific coast

or in the outer Arctic reaches of Siberia Many believed that Moscow was cheating on its end of the deal, and thus that the treaty should go

In the 1980s tensions between the United States and the Soviet Union flared In October

1985 the Reagan administration announced a new interpretation of the ABM Treaty, under which the development and testing of “exotic”

ABM systems (those not spelled out in the treaty itself, e.g., Star Wars) would have no limit In 1986, with the Strategic Arms Reduc-tion Treaty (START) talks in full swing, the United States and the Soviet Union treated the ABM Treaty as a central bargaining chip

Moscow looked to maintain the treaty for at least another decade, with tight constraints on space testing Washington, meanwhile, looked

to abide by the treaty for, at most, another decade and expected lessened constraints on the space testing of exotic technologies

U.S President Richard Nixon and Soviet President Leonid Brezhnev sign the Anti-Ballistic-Missile Treaty in Moscow on May 26, 1972.

AP IMAGES ANTI-BALLISTIC-MISSILE TREATY OF 1972 309

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The ensuing events of the late 1980s and early 1990s caught everyone by surprise

Although the United States’ interest in the SDI continued into the George H W Bush administration years, and persisted through the eventual breakup of the Soviet Union, both the United States and the Soviet Union showed interest in pursuing at least the spirit of the ABM Treaty True arms-reduction talks devel-oped with the Soviet demise In 1991 Soviet nuclear forces were split up among four countries—Russia, Ukraine, Belarus, and Kazakhstan—and spokespersons on both sides saw revision of the ABM Treaty as necessary

The START agreements of 1992 shed new light

on older concessions As the chief U.S architect

of the original ABM Treaty,HENRY KISSINGERnow joined others in declaring it obsolete in the new era of disarmament As a gesture ofGOOD FAITH, the Soviets demolished their controversial Krasnoyarsk radar system; a shoe factory now occupies the site

In the years that followed, the United States and Russia both worked together and strayed from the MAD doctrine They also turned their attention elsewhere, mainly to the developing world New nations on the list of nuclear powers included Israel, India, Pakistan, Algeria, Egypt, Iran, Iraq, Libya, North Korea, and Syria, none of which had any formal attachment to the ABM Treaty U.S and former Soviet strategists went from analyzing BMD research provisions set forth in the ABM Treaty to setting up safeguards against attack from other powers

In December 2001, however, the United States announced that it would no longer follow the ABM treaty The withdrawal came after months of failed negotiations with Russia to jointly abandon the ABM treaty and to craft a new pact based on the current world situation

The formal announcement by PresidentGEORGE

W BUSH set in motion a six-month period for ending the pact He stated that the ABM Treaty

“hinders our government’s ability to develop ways to protect our people from future terrorist

or rogue state missile attacks.”

On June 13, 2002, the United States officially withdrew from the ABM Treaty In response to the United States withdrawal, the following day Russia announced that it would

no longer be bound by the START II Strategic Arms Reduction Treaty that was signed by both President GEORGE H.W BUSH and Russian

President Boris Yeltsin on January 3, 1993 However, Russia’s decision to pull out from START II had no real impact, as the terms of that treaty had been superseded by the Strategic Offensive Reductions Treaty (SORT) SORT was entered into by President George W Bush and Russian President Vladimir Putin on May 24,

2002, and was ratified on June 1, 2003 Under that treaty, both countries agreed to reduce their strategic nuclear warheads by 2012 Although Putin expressed regret at the United States’ decision to withdraw from the ABM Treaty, he did not signal a move to build a competing system Putin was not the only person to express regret President George W Bush’s decision to withdraw from the ABM Treaty was met with criticism by members of the United States House of Representatives Thirty-two members

of the House of Representatives, led by Ohio Representative Dennis Kucinich, filed a lawsuit against President George W Bush, charging that

he did not have the authority to unilaterally withdraw the United States from the ABM treaty without congressional approval The district court dismissed the case and ruled that the members of the House of Representatives did not have any standing to challenge President Bush’s decision, because they were not person-ally injured by the president’s act, and because the issue of a treaty termination is a “political question” that cannot be resolved by the courts The Bush administration made it clear that the United States’ withdrawal from the treaty was motivated by the desire to build and deploy

a long-range missile defense system that would protect the nation from attacks by rogue nations such as North Korea and Iran The deployment

of the missile shield system was set for 2004 and was planned to have a missile radar system placed in the Czech Republic as well as 10 long-range missile interceptors in Poland On September 17, 2009, however, President Barack Obama’s administration announced that it was eliminating the original plans of the Bush Administration’s long-range missile defense system to implement a system that favors more flexible, short-range systems that will counter potential short- or mid-range European missile

THREATSfrom Iran

FURTHER READINGS American-Soviet Treaty on the Limitation of Anti-Ballistic Missile Systems May 26, 1972 Moscow.

310 ANTI-BALLISTIC-MISSILE TREATY OF 1972

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Assembly of Western European Union 1993 Anti-Missile

Defence for Europe, Symposium, Rome, April 20 –21.

Blackwill, Robert D., and Albert Carnesale, eds 1993 New

Nuclear Nations New York: Council on Foreign

Relations.

Boese, Wade “U.S Withdraws from ABM Treaty; Global

Response Muted ” Arms Control Association Available

online at http:// www.armscontrol.org/print/1071

web-site home page: http://www.armscontrol.org (accessed

September 24, 2009).

Durch, William J 1988 The ABM Treaty and Western

Security Cambridge, Mass.: Ballinger.

——— 1987 The Future of the ABM Treaty London:

International Institute for Strategic Studies.

Greenville, J.A.S., and Bernard Wasserstein 1987 The Major

International Treaties Since 1945 London: Methuen.

Joint Chiefs of Staff 1994 Doctrine for Joint Theater Missile

Defense Joint pub no 3-01.5, March 30.

“Judge Allows Bush’s Withdrawal from ABM Treaty to

Stand: Leaves Open Possibility of Future Congressional

Role in Treaty Termination ” Lawyers Committee on

Nuclear Policy Available online at http://lcnp.org/

disarmament/ABMlawsuit/ABMdecisionpr.pdf website

home page: http://www.lcnp.org (accessed September

24, 2009).

Kartchner, Kerry M 1992 Negotiating START New

Brunswick, N.J., and London: Transaction.

Martinez, Luis, Raddatz, Martha, Compton, Ann

Septem-ber 17, 2009 “Obama: New European Missile Plan will

Strengthen U.S Defenses ” ABCNews.com Available

online at http://abcnews.go.com/print?id=8599260.

Website home page: http://abcnews.go.com (accessed

September 24, 2009).

Mazarr, Michael J., and Alexander T Lennon, eds., 1994.

Toward a Nuclear Peace New York: St Martin’s Press.

Perez-Rivas, Manuel December 14, 2001 “U.S Quits ABM

Treaty ” CNN.com: Inside Politics Available online at

www.cnn.com/2001/ALLPOLITICS/12/13/rec.bush.

abm/index.html (accessed May 30, 2003).

Voas, Jeanette 1990 Soviet Attitudes towards Ballistic Missile

Defence and the ABM Treaty London: International

Institute for Strategic Studies.

CROSS REFERENCES

Arms Control and Disarmament; Bush, George Herbert

Walker; International Law

ANTI-DEFAMATION LEAGUE

The Anti-Defamation League (ADL) is an agency

of B’snai B’srith, an international Jewish service

organization The ADL combats anti-Semitism,

religious and racial intolerance, and all forms of

organized discrimination based on stereotypical

beliefs The ADL also is a strong advocate of the

state of Israel,LOBBYING Congress in support of

legislation that benefits the Jewish State It has its

headquarters in New York City and has regional

and satellite offices throughout the United States

The ADL also has offices in Jerusalem and Vienna

Sigmound Livingston founded the ADL in

1913 with the support of B’snai B’srith

Livingston, a Chicago attorney, stated that the mission of the league was“to stop, by appeals to reason and conscience, and if necessary, by appeals to law, the DEFAMATION of the Jewish people to secure justice and fair treatment to all citizens alike [and] put an end forever to unjust and unfair discrimination against and ridicule of any sect or body of citizens.”

The ADL first gained recognition by taking steps to eradicate negative stereotypes of Jews in print and their stereotyping on stage and in film By the early 1920s, objectionable refer-ences to Jews in the national press had virtually disappeared However, popular culture was filled with negative stereotypes of Jews The rise

of the KU KLUX KLANin the 1920s was based as much on anti-Semitism as racial intolerance

The ADL responded by circulating pamphlets that challenged hatred of Jews and demanded apologies from prominent citizens, such as automobile manufacturer Henry Ford, for endorsing anti-Semitic views

With the rise of Nazism in the 1930s, the ADL fought U.S supporters of Hitler who endorsed his anti-Semitic policies During this decade, the ADL began to collect information on extremist indivi-duals and organizations and to monitor and investigate fascist groups in the United States

These fact-finding and monitoring activities have remained a central part of the ADL’s work

Since the 1940s, the ADL has lobbied for

CIVIL RIGHTS legislation, filed briefs in courts supporting the SEPARATIONof church and state, and educated succeeding generations in reli-gious tolerance Since the creation of Israel in

1948, the ADL has also defended Israel’s right to exist and has fought against anti-Zionism In the 1990s, the organization began monitoring theINTERNETfor evidence of anti-Semitism and right-wing extremism In 2000 the ADL issued a report titled “Combating Extremism in Cyber-space,” a review of legal issues raised by hate groups using the Internet The ADL’s monitor-ing of the Internet and other forms of communication took on new urgency in light

of the events surrounding the SEPTEMBER 11TH ATTACKS of 2001 on the United States In addition to the many other issues concerning the ADL including school vouchers and Presi-dent George W Bush’s “Faith Based Initiative”

to allow certain charities to receive federal funds, the ADL Internet site features a “Terror-ism Update.” The ADL has also created a

ANTI-DEFAMATION LEAGUE 311

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handbook with suggestions for keeping Jewish institutions safe from terrorist attacks

The ADL is divided into numerous groups and departments The Civil Rights Division is the most prominent wing of the organization, as

it has investigated and exposed anti-Semitism and bigotry The division’s research department has become a central source of information on organized bigotry, collecting and analyzing racist, anti-Semitic, terrorist, and extremist literature The department issues an annual Audit of Anti-Semitic Incidents that serves as a reliable measurement tool of anti-Semitic trends The Civil Rights Division’s fact-finding department uses investigative journalists to track the activities of extremist groups For example, this department tracked neo-Nazi skinhead activity in 33 countries and issued the first major survey on this movement

The Civil Rights Division’s legal affairs department serves as the ADL’s advocate in court and before legislatures The department’s attorneys file briefs, analyze proposed bills and regulations, draft model laws, and prepare

TESTIMONY and legal reports for ADL staff The department’s model hate crimes law has been adopted by almost four-fifths of the states and has been upheld as constitutional by the U.S

Supreme Court in State v Mitchell, 508 U.S

476, 113 S Ct 2194, 124 L.Ed.2d 436 (1993) In addition, the department works with local attorneys in the ADL’s thirty regional offices

The ADL’s Braun Holocaust Institute, estab-lished in 1977, serves as a centralized information center on the Holocaust The institute encourages public and religious schools to teach about the Holocaust by providing curricula for elementary and high school students It has also organized teacher-training workshops and semi-nars to help teachers incorporate Holocaust studies into mainstream disciplines The insti-tute’s collection of Holocaust-related materials is recognized as one of the best in the world In addition, the institute publishes Dimensions: A Journal of Holocaust Studies, a general interest magazine on the Holocaust, and resource guides, catalogs, and background primers

The Government and National Affairs Office

in Washington, D.C., serves as the ADL’s lobbyist, promoting the legislative agenda of the organization The office worked with Congress to establish a congressional task force against anti-Semitism The ADL has also led a broad coalition

of civil rights, religious, and law enforcement groups in support of federalHATE CRIMEinitiatives

In addition, the ADL has fought against federal school voucher programs and has sought to increase workplace protection for employees who wish to observe their religious duties The ADL’s commitment to the state of Israel includes maintaining an office in Jerusalem This office provides information on current issues to ADL staff and members, and it communicates the U.S Jewish community’s concerns to the Israeli government The Jerusalem office also intro-duces visiting Americans, such as government officials and journalists, to the people and politics

of Israel The ADL has endorsed the need for a just peace between Israelis and Palestinians but has been an adamant defender of Israel and opponent ofTERRORISM

FURTHER READINGS Anti-Defamation League Web site Available online at http:// www.adl.org (accessed July 4, 2009).

Levin, Jack, and Jack McDevitt 2002 Hate Crimes Revisited New York: Westview.

Stern-Larosa, Caryl, and Ellen Hoffheimer-Bettmann 2001 Anti-Defamation League’s Hate Hurts: How Children Learn and Unlearn Prejudice New York: Scholastic CROSS REFERENCES

Hate Crime; Hate Crime: “Do Hate Crime Laws Restrict First Amendment Rights? ” (In Focus); Libel and Slander. ANTICIPATION

The performance of an act or obligation before it is legally due In patent law, the publication of the existence of an invention that has already been patented or has a patent pending, which are grounds for denying a patent to an invention that has substantially the same structure and function

as the earlier invention

In the law ofNEGLIGENCE, anticipation refers to the knowledge that there is a reasonable proba-bility that the consequences of particular conduct

of one individual will result in injury to others The anticipation of an invention also occurs

if the later invention is merely anADAPTATIONof

an earlier patent, which would be obvious to a skilled person who need only exercise some mechanical skill to develop the same adaptation

ANTICIPATORY REPUDIATION The unjustifiable denial by a party to a contract of any intention to perform contractual duties, which occurs prior to the time performance is due

312 ANTICIPATION

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This form of breach, also known as

anticipatory breach of contract, occurs when

one party positively states that he or she will not

substantially perform a contract The mere

assertion that the party is encountering

difficul-ties in preparing to perform, is dissatisfied with

the bargain, or is otherwise uncertain whether

performance will be rendered when due is

insufficient to constitute aREPUDIATION Another

type of anticipatory breach consists of any

VOLUNTARY ACT by a party that destroys, or

seriously impairs, that party’s ability to perform

the contract

The remedies available to the

nonrepudiat-ing party upon an anticipatory repudiation

entail certain obligations If the nonrepudiating

party chooses to ignore the repudiation and

proceeds with his or her performance, the duty

to mitigate damages—which imposes on the

injured party an obligation to exercise

reason-able effort to minimize losses—mandates that

the nonrepudiating party not perform if the

consequence of performance would be to

increase the damages In addition, this duty

requires, where applicable, the procurement of

a substitute performance

If the nonrepudiating party implores or

insists that the other party perform, this

demand, in and of itself, does not divest the

nonrepudiating party’s right to damages The

presence or absence of a breach of contract

depends solely upon the repudiating party’s

actions The prevailing view is that the

non-repudiating party may pursue any remedy for

breach of contract, even though he or she has

informed the repudiating party that he would

await the latter’s performance

The nonrepudiating party also possesses the

option to do nothing and to commence an

action for breach after the time for

perfor-mance Under the majority view, such an action

can be instituted without tendering the

non-repudiating party’s performance or even

alleg-ing or provalleg-ing that the party was ready, willalleg-ing,

and able to perform The nonrepudiating party

must demonstrate, however, that he or she

would have been ready, willing, and able to

perform but for the repudiation

In regard to the law of sales, the UNIFORM

COMMERCIAL CODE(UCC), a body of law

govern-ing commercial transactions by the states,

provides that anticipatory repudiation entails

the right of one party to a contract to sue for

breach before the performance date when the other party communicates the intention not to perform The repudiation can, however, be retracted before the performance date if the nonrepudiating party has not acted on the basis

of the repudiation Some jurisdictions direct the injured party to await the performance date before instituting an action

ANTILAWYER MOVEMENT Throughout early U.S history, legal practi-tioners were the subject of ambivalence on the part of the general public The attitude against lawyers reached its peak after the Revolutionary War and remained hostile until the beginning of the nineteenth century

During the early days of the colonies, the system for the administration of justice was based on arbitration and religious principles, and lawyers specially educated and skilled in the law were presumably not needed and were often restricted or prohibited from practicing Judges were ordinary men who used unpolished methods of questioning to determine the facts

of each case; defendants were their own lawyers

This system remained successful as long as the population of each community remained small and manageable, and the people were clear about their rights and obligations to their neighbors and the community

By the end of the seventeenth century, the colonies experienced a period of growth, and the original judicial system became unsatisfac-tory FormalPLEADINGand skilled lawyers began

to replace the primitive methods of earlier colonial times

After the Revolutionary War, Americans sought a new form of jurisprudence to interact with their newly gained freedoms Laws were less confining, due to the belief that moral fiber was more important to satisfactory conduct than legislation

During this period, the antilawyer move-ment gained momove-mentum Historians speculate that it evolved as a result of former prejudices and conflicts toward the legal profession

Although lawyers in the past had not been viewed favorably, they achieved prominence and esteem as strong proponents of freedom from England during the Revolutionary War

After the war, lawyers were once again an important part of the legal system but were used

ANTILAWYER MOVEMENT 313

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primarily by the wealthy As a result, they were often in conflict with those who were poor and could not pay their debts, which led to a resurrection of the old negative attitudes against them

Lawyers were regarded with suspicion They were accused of initiating unnecessary lawsuits, impeding the justice system, and prolonging trials to secure additional fees from unsuspect-ing clients They were also criticized for the use

of legal jargon, causing simple matters to seem complicated

Despite these attacks, lawyers managed to attain political power They were regarded as conspirators, however, for people could not accept the idea that lawyers who served as politicians made the laws by which they secured

a living as legal practitioners It was also feared that lawyers, judges, and legislators would band together to control society, depriving the

common people of some of their hard-won freedoms Although the fears were exaggerated, they were true to some degree, for lawyers did earn a living from the ramifications that legislation had upon the general public Two remedies were recommended to rec-oncile the proponents of the antilawyer senti-ment and lawyers The first suggestion was an updated version of the early colonial justice system, which prohibited lawyers from practic-ing A judge representing the interests of the community would preside over the court and instruct the jury Judges were educated aristo-crats who could be impeached if their conduct

so warranted If a LEGAL REPRESENTATIVE was deemed necessary, a friend of the DEFENDANT

could participate in the arbitration

The second suggestion provided for a small group of professional lawyers to practice as public servants Their salaries and actions would

be controlled by the state, and their chief function would be to clarify legal principles of each case for the jury

The conflicting feelings toward lawyers culminated in several incidents, the most noteworthy of which was known as Shays’s Rebellion The rebellion began in 1786 when Massachusetts voters elected a majority of nonlawyers to the General Court This action led to aRIOT, and hostile agrarian mobs overran the courthouses, closing them down The governor dispatched the state army, which successfully quelled the agitators

Shays’s Rebellion did not stop the people of Massachusetts from electing lawyers to political positions The very tactics they feared in the courtroom were highly desirable in politics to control government officials; in spite of their conflicting feelings, voters were still attracted to legal skills

The new methods of justice proved to be inefficient Arbitration was fruitless, and laymen were fallible as lawyers By 1790, most cases were again tried by lawyers, and the antilawyer movement began to wane

CROSS REFERENCE Shays ’s Rebellion.

ANTINOMY

An expression in law and logic to indicate that two authorities, laws, or propositions are inconsistent with each other

A wood engraving

from an 1884

Harper’s Monthly

shows Daniel Shays

and his comrades

occupying a

Massachusetts

courthouse to prevent

the court from

directing legal action

at debt-ridden

farmers in 1786.

BETTMANN/CORBIS.

314 ANTINOMY

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ANTITRUST LAW

Antitrust law refers to legislation enacted by the

federal and various state governments to regulate

trade and commerce by preventing unlawful

restraints, price-fixing, and monopolies; to

pro-mote competition; and to encourage the

produc-tion of quality goods and services at the lowest

prices, with the primary goal of safeguarding

public welfare by ensuring that consumer

demands will be met by the manufacture and

sale of goods at reasonable prices

Antitrust law seeks to make enterprises

compete fairly It has had a serious effect on

business practices and the organization of U.S

industry Based on the belief that free trade

benefits the economy, businesses, and

consu-mers alike, the law forbids several types of

RESTRAINT OF TRADE and monopolization These

fall into four main areas: agreements between or

among competitors, contractual arrangements

between sellers and buyers, the pursuit or

maintenance of monopoly power, and mergers

The Sherman Anti-Trust Act of 1890 (15

U.S.C.A § 1 et seq.) is the basis for U.S

antitrust law, and many states have modeled

their own statutes upon it As weaknesses in the

Sherman Act became evident, Congress added

amendments to it at various times through

1950 The most important are theCLAYTON ACT

of 1914 (15 U.S.C.A § 12 et seq.) and the

ROBINSON-PATMAN ACTof 1936 (15 U.S.C.A § 13

et seq.) Congress also created a regulatory

agency to administrate and enforce the law,

under theFEDERAL TRADE COMMISSIONAct of 1914

(15 U.S.C.A §§ 41–58) In an ongoing analysis

influenced by economic, intellectual, and

polit-ical changes, the U.S Supreme Court has played

the leading role in shaping the ways in which

these laws are applied

Enforcement of antitrust law depends largely

on two agencies: the Federal Trade Commission

(FTC), which may issue cease-and-desist orders

to violators, and the Antitrust Division of the

U.S DEPARTMENT OF JUSTICE (DOJ), which can

litigate Private parties may also bring civil suits

Violations of the Sherman Act are felonies

carrying fines of up to $10 million for

corporations, and fines of up to $350,000 and

prison sentences of up to three years for

persons The federal government, states, and

individuals may collect treble (i.e., triple) the

amount of damages that they have suffered as a

result of injuries

Origins Antitrust law originated in reaction to a public outcry over trusts, which were late-nineteenth-century corporate monopolies that dominated U.S manufacturing and mining Trusts took their name from the legal device of business incorporation called trusteeship, which consoli-dated control of industries by transferring stock

in exchange for trust certificates The practice grew out of necessity Twenty-five years after the Civil War, rapid industrialization had blessed and cursed business Markets expanded and productivity grew, but output exceeded demand, and competition sharpened Rivals sought greater security and profits in cartels (mutual agreements to fix prices and control output) Out of these arrangements sprang the trusts From sugar to whiskey to beef to tobacco, the process of merger and consolida-tion brought entire industries under the control

of just a few powerful people Oil and steel, the backbone of the nation’s heavy industries, lay in the hands of the corporate giants John D

Rockefeller and J P Morgan The trusts could fix prices at any level If a competitor entered the market, the trusts would sell their goods at a loss until the competitor went out of business, and then they would raise prices again By the 1880s, abuses by the trusts brought demands for reform

History gave only contradictory direction to the reformers Before the eighteenth century,

During a December

1998 news conference

in Washington, D.C., Bill Gates, founder of Microsoft, answers questions, via closed-circuit television, about the antitrust lawsuit filed against the company.

AP IMAGES ANTITRUST LAW 315

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COMMON LAW concerned itself with contracts, combinations, and conspiracies that resulted in restraint of free trade, but it did little about them English courts generally let restrictive contracts stand because the courts did not consider themselves to be suited to judging adequacy or fairness Over time, courts looked more closely into both the purpose and the effect of any restraint of trade The turning point came in 1711 with the establishment of the basic standard for judging close cases, “the rule of reason.” Courts asked whether the goal

of a contract was a general restraint of competition (a naked restraint) or particularly limited in time and geography (an ancillary restraint) Naked restraints were unreasonable, but ancillary restraints were often acceptable

Exceptions to the rule grew as the economic philosophy of laissez-faire economics (meaning

“let the people do what they please”) spread its doctrine of non-interference in business As rival businesses formed cartels to fix prices and

to control output, the late-eighteenth-century English courts often nodded in approval

By the time the U.S public was complaining about the trusts, common law in U.S courts was somewhat tougher on restraint of trade Yet

it was still contradictory The courts took two

basic views of cartels: tolerant and condemning The first view accepted cartels as long as they did not stop other merchants from entering the market This view used the rule of reason to determine this, and it put a high premium on the freedom to enter into contracts Businesses and contracts mattered Consumers, who suf-fered from price-fixing, were irrelevant; the wisdom of the market would protect them from exploitation The second view was that cartels are thoroughly bad It reserved the rule of reason only for judging more limited ancillary restrictions Given these competing views, which varied from state to state, no compre-hensive common law could be said to exist But one approach was destined to win

The Sherman Act and Early Enforcement

In 1890, Congress took aim at the trusts with passage of the SHERMAN ANTI-TRUST ACT, named for SenatorJOHN SHERMAN (R-Ohio) It went far beyond the common law’s refusal to enforce certain offensive contracts Clearly persuaded by the more restrictive view that saw great harm in restraint of trade, the Sherman Act outlawed trusts altogether The LANDMARK law had two sections Section 1 broadly banned group action

in agreements, forbidding “every contract, combination in the form of trust or otherwise,

or conspiracy,” that restrained interstate or foreign trade Section 2 barred individuals from monopolizing or trying to monopolize Viola-tions of either section were punishable by a maximum fine of $50,000 and up to one year in jail The Sherman Act passed by nearly unani-mous votes in both houses of Congress Although sweeping in its language, the Sherman Act soon revealed its limitations Congress had wanted action even though it did not know what steps to take Historians would later dispute what its precise aims had been, but clearly the lawmakers intended for the courts to play the leading role in promoting competition and attacking monopolization: Judges would make decisions as cases arose, slowly developing a body of opinions that would replace the confusing precedents of state courts For a public that expected overnight change, the process worked all too slowly President Grover Cleveland’s Department of Justice, which disliked the Sherman Act, made little effort to enforce it

Initial setbacks also came from the U.S Supreme Court’s first consideration of the

This political cartoon

depicts President

Theodore Roosevelt

resurrecting the

Sherman Anti-Trust

Act Roosevelt’s

administration filed

44 antitrust lawsuits

in eight years.

316 ANTITRUST LAW

Trang 10

statute, in United States v E C Knight Co., 156

U.S 1, 15 S Ct 249, 39 L Ed 325 (1895)

Rejecting a challenge to a sugar trust that

controlled more than 98 percent of the nation’s

sugar-refining capacity, the Court held that

manufacturing was not interstate commerce

This was good news for trusts If manufacturers

were exempt from the Sherman Act, then they

would have little to worry about from federal

antitrust regulators The Court only began

strongly supporting the use of the law in the

late 1890s, starting with cases against railroad

cartels By 1904 some 300 large companies still

controlled nearly 40 percent of the nation’s

manufacturing assets and influenced at least 80

percent of its vital industries

After the turn of the twentieth century,

federal enforcement intensified President

Theodore Roosevelt’s announcement that he

was a “trustbuster” foreshadowed one

impor-tant aspect of the future of antitrust

enforce-ment: It would depend largely on political will

from the Executive Branch of government

Roosevelt and his successor, President WILLIAM

HOWARD TAFT, responded to public criticism over

the rapid merger of even more industries by

pursuing more vigorous legal action Steady

prosecution in the first decade of the twentieth

century brought the downfall of trusts

In 1911 the U.S Supreme Court ordered

the dissolution of the Standard Oil Company

and the American Tobacco Company in

landmark rulings that brought down two of

the most powerful industrial trusts But these

were ambiguous victories In Standard Oil Co of

New Jersey v United States, 221 U.S 1, 31 S Ct

502, 55 L Ed 619, for example, the Court

dissolved the trust into 33 companies, but held

that the Sherman Act outlawed only restraints

that were anticompetitive—subject,

further-more, to a rule of reason Critics of all stripes

jumped on this decision Some feared that

conservative judges would now gut the Sherman

Act; others predicted a return to lax

enforce-ment; and businesses worried that in the

absence of specific unlawful restraints, the rule

of reason gave courts too much freedom to read

the law subjectively

Congressional Reform up to 1950

Dissatisfaction brought new federal laws in

1914 The first of these was the Clayton Act,

which answered the criticism that the Sherman

Act was too general It declared four practices to

be illegal but not criminal: (1) price discrimi-nation—selling a product at different prices

to similarly situated buyers; (2) tying and exclusive-dealing contracts—sales on condition that the buyer stop dealing with the seller’s competitors; (3) corporate mergers—acquisitions

of competing companies; and (4) interlocking directorates—boards of competing companies, with common members

Quick to hedge its bets, the Clayton Act qualified each of these prohibited activities

They were only illegal where the effect“may be substantially to lessen competition” or “might tend to create a monopoly.” This language was intentionally vague Despite specifying different tests for violations, Congress still wanted the courts to make the difficult decisions One important limitation was added: The Clayton Act exempted unions from the scope of antitrust law, refusing to treat human labor as

a commodity

The second piece of federal legislation in

1914 was the Federal Trade Commission Act

Without attaching criminal penalties, the law provided that“unfair methods of competition in

or affecting commerce, and unfair or deceptive acts or practices in or affecting commerce are hereby declared illegal.” This was more than a symbolic attempt to buttress the Sherman Act

The law also created a regulatory agency, the Federal Trade Commission (FTC), to interpret and enforce it Lawmakers who feared judicial hostility to the Sherman Act saw the FTC as a body that would more closely follow their preferences Originally, the commission was designed to issue prospective decrees and to share responsibilities with the Antitrust Division

of the Department of Justice Later court rulings would allow it greater latitude in attacking Sherman Act violations

These laws helped to satisfy the short-term demand for tougher, more explicit action from Congress Before long, antitrust enforcement would shift with the mood of the country As

WORLD WAR Iand the 1920s reversed the outlook

of previous years, antitrust policy was charac-terized by the hands-off policies of President

CALVIN COOLIDGE, who declared, “The chief business of the American people is business.” Economic trends created and supported this attitude; prosperity seemed a worthwhile re-ward In this era, the DOJ gave more attention

to promoting fairness than it did to attacking

ANTITRUST LAW 317

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