In the 1914 case of Evens and Howard Fire Brick Company v. United States, the Supreme Court ruled on an issue related to antitrust law. The court found that a combination of fire brick manufacturers who controlled over 80% of the market had violated the Sherman Antitrust Act by engaging in price fixing and limiting production to control prices. The defendants argued that their actions were necessary due to foreign competition and fluctuating demand for their product, but these arguments were rejected by the court as irrelevant under antitrust law. Furthermore, they claimed they did not restrain trade because they did not prevent anyone from manufacturing or selling fire bricks; however, this argument was also dismissed since it was clear that their activities significantly restrained commerce among states which is prohibited under federal law.

In the dissenting opinion for Evens and Howard Fire Brick Company v. United States, it was argued that the Sherman Anti-Trust Act should not be applied to labor unions as they are not commercial organizations engaged in trade or commerce. The dissenting justices believed that a union's primary purpose is to protect workers' rights and improve working conditions, rather than engage in business activities for profit. They contended that applying anti-trust laws to labor unions could potentially undermine their ability to effectively advocate for workers' interests. Furthermore, they disagreed with the majority's interpretation of "restraint of trade," arguing that this term should only apply to actions which unreasonably restrict competition or manipulate market prices, neither of which were relevant in this case involving a strike by bricklayers demanding higher wages.