In the case of Lehigh Valley Cooperative Farmers, Inc. v. United States in 1961, the Supreme Court ruled that a cooperative organization was not exempt from federal antitrust laws simply because it was a cooperative. The Lehigh Valley Cooperative Farmers had been accused by the U.S Department of Justice for violating antitrust laws through price-fixing and market allocation agreements with other egg producers and distributors in Pennsylvania and New Jersey. The farmers argued that as a cooperative they were immune to these charges under Section 6 of the Clayton Act which exempts agricultural organizations from such prosecution. However, this argument was rejected by both lower courts and eventually by the Supreme Court itself on appeal; stating that while cooperatives may be protected when acting alone or with their members, they are not immune when conspiring with independent competitors to restrain trade.

In the dissenting opinion for Lehigh Valley Cooperative Farmers, Inc. v. United States et al., it was argued that the majority's decision to uphold an order by the Secretary of Agriculture underestimates and undermines Congress' intent in passing legislation regulating milk marketing orders. The dissenters believed that while Congress intended to protect dairy farmers from price exploitation, they did not intend for this protection to extend so far as to allow a single farmer or group of farmers to monopolize an entire market area through government-sanctioned pricing regulations. They contended that such interpretation would lead towards economic inefficiency and unfairness, with consumers bearing excessive costs due to artificially high prices set by these monopolies. Furthermore, they criticized the majority’s reliance on broad interpretations of statutory language rather than clear legislative history or precedent in reaching their conclusion.