In the case of Eastern States Retail Lumber Dealers' Association v. United States, 1913, the U.S Supreme Court ruled that a group boycott organized by a trade association to pressure manufacturers into not selling directly to consumers was in violation of the Sherman Antitrust Act. The Eastern States Retail Lumber Dealers' Association had created a "blacklist" of manufacturers who sold directly to consumers and encouraged its members not to do business with those on this list. The court found that such actions constituted an illegal restraint on trade as they were designed to suppress competition and create monopolies. This decision reinforced the principle that any agreement or understanding among businesses which unreasonably restricts commerce can be deemed unlawful under antitrust laws.

In the dissenting opinion for Eastern States Retail Lumber Dealers' Association v. United States, it was argued that the majority's interpretation of the Sherman Act was too broad and could potentially criminalize normal business activities. The dissenters believed that not all restraints on trade were necessarily harmful or illegal, especially if they did not involve monopolistic practices or attempts to fix prices. They also contended that there should be a distinction between agreements among competitors which directly restrict competition and those which only indirectly affect it, with only the former being subject to antitrust laws. Furthermore, they expressed concern about potential negative impacts on freedom of contract and economic liberty if businesses had to constantly fear prosecution under an overly expansive interpretation of antitrust legislation.