In the Radiant Burners, Inc. v. Peoples Gas Light & Coke Co., et al., 1960 case, Radiant Burners, a gas burner manufacturer, alleged that it was denied certification by American Gas Association (AGA) due to a conspiracy among AGA members including Peoples Gas Light and Coke Company. The denial of certification resulted in utility companies refusing to install or service its burners causing significant business loss for Radiant Burners. The Supreme Court ruled in favor of Radiant Burner's claim stating that if proven true, these actions would violate the Sherman Antitrust Act which prohibits activities restricting interstate commerce and competition in the marketplace. This decision reversed previous rulings from lower courts dismissing the complaint on grounds that no direct injury had been inflicted upon any customers or competitors within individual states - an interpretation of antitrust laws at odds with their intended purpose according to Justice Black who delivered this opinion.

In the dissenting opinion for Radiant Burners, Inc. v. Peoples Gas Light & Coke Co., Justice Frankfurter disagreed with the majority's decision to allow a private party to sue under antitrust laws without demonstrating any harm to competition or public interest. He argued that the Sherman Act was not intended as a general remedy for all wrongs but specifically aimed at protecting consumers from monopolistic practices and maintaining competitive markets. The plaintiff in this case, according to him, failed to show how its exclusion from an industry-wide certification program harmed competition or violated antitrust laws since it could still sell its products independently. Furthermore, he criticized the majority's reliance on 'conspiracy' allegations which were unsupported by substantial evidence and warned against turning courts into "forums for business negotiations".