In the 1910 case of Dr. Miles Medical Company v. John D. Park & Sons Company, the U.S Supreme Court ruled that it was illegal for a manufacturer to set minimum resale prices for its products by agreement with its distributors - a practice known as vertical price-fixing or resale price maintenance (RPM). The court held that such agreements were in violation of the Sherman Antitrust Act because they restricted competition and interfered with free trade. This decision established an important precedent in antitrust law, making RPM per se illegal under federal law until this rule was overturned nearly a century later by Leegin Creative Leather Products Inc v PSKS Inc., which allowed manufacturers to engage in RPM under certain conditions.

In the dissenting opinion of Dr. Miles Medical Company v. John D. Park & Sons Company, Justice Holmes argued that the majority's decision was based on an outdated understanding of economic theory and failed to recognize the legitimate business interests at stake for manufacturers like Dr. Miles Medical Company in controlling resale prices of their products by retailers such as John D. Park & Sons Co.. He contended that a manufacturer should be able to decide under what conditions it would sell its goods, including setting minimum resale prices, without violating antitrust laws unless there is evidence of monopolistic intent or effect which he didn't see in this case.