The U.S. Supreme Court case Catalano, Inc., et al. v. Target Sales, Inc., et al., 1979 revolved around an agreement between beer wholesalers to stop giving credit to retailers for their purchases of beer products. The plaintiffs argued that this was a violation of the Sherman Antitrust Act as it restrained trade and competition in the market by eliminating price competition based on terms of sale rather than just product prices themselves. The defendants countered that they were simply standardizing business practices which did not affect pricing or output levels directly, hence should be exempt from antitrust laws under the rule-of-reason doctrine (which allows some coordinated actions among businesses if they promote overall market competitiveness). However, the Supreme Court ruled against them stating that such agreements are illegal per se under antitrust law because they limit consumer choices and hinder competitive strategies among businesses even if no immediate effect on prices is evident.

In the dissenting opinion for Catalano, Inc. v. Target Sales, Inc., Justice Rehnquist disagreed with the majority's view that an agreement among competitors to adopt a specific credit term was per se illegal under Section 1 of the Sherman Act. He argued that such agreements should be evaluated under a rule of reason analysis instead. According to him, not all agreements among competitors have anti-competitive effects or necessarily restrict competition in violation of antitrust laws; some may even promote competition by allowing smaller firms to compete more effectively against larger ones. Therefore, he believed it was inappropriate and overly simplistic to categorically condemn all such agreements as per se violations without considering their actual impact on market competition.