In the case of United States v. N.Y. Rayon Importing Co., Inc., the Supreme Court ruled in 1946 that a corporation could be held criminally liable for actions taken by its employees, even if those actions were not explicitly authorized by company leadership. The New York Rayon Importing Company was charged with violating federal laws related to price control during World War II when some of its employees sold rayon at higher prices than allowed under wartime regulations. The company argued it should not be held responsible because these sales were made without management's knowledge or approval, but the court disagreed and upheld their conviction.

In the dissenting opinion for UNITED STATES v. N. Y. RAYON IMPORTING CO., INC., Justice Frankfurter disagreed with the majority's interpretation of Section 2(c) of the Clayton Act, which prohibits price discrimination that may lessen competition or create a monopoly in any line of commerce. He argued that this provision should not be applied to foreign trade because it was intended to regulate domestic commerce and protect American consumers from harmful business practices within U.S borders, not abroad. According to him, extending its scope beyond these boundaries would interfere with international trade relations and potentially harm American exporters by imposing on them restrictions meant for domestic businesses only.