In the United States v. First National Pictures, Incorporated et al., 1930, the Supreme Court dealt with an antitrust case involving movie distribution companies and independent film exhibitors. The plaintiffs alleged that defendants had conspired to monopolize trade in violation of the Sherman Antitrust Act by creating a system where only certain theaters could show their films. This effectively barred independent exhibitors from accessing popular movies, thereby limiting competition. However, the court ruled in favor of First National Pictures and other defendant distributors on grounds that there was insufficient evidence to prove conspiracy or intent to monopolize trade among them as required under law for such allegations to hold up in court.

The dissenting opinion in the case of United States v. First National Pictures, Inc., argued that the majority's decision to uphold a lower court ruling dismissing an antitrust lawsuit against several major film studios was incorrect. The dissent contended that there was sufficient evidence to suggest these companies were engaging in monopolistic practices and violating federal antitrust laws by controlling both production and distribution aspects of their films, thereby limiting competition within the industry. They believed this control over multiple stages of business operation constituted a restraint on trade as it effectively barred independent producers from entering or competing fairly in the market. Therefore, they felt that such behavior should be subject to scrutiny under antitrust legislation rather than being dismissed outright by courts without proper examination.