In the case of United States v. Purcell Envelope Company in 1918, the Supreme Court ruled on whether a corporation could be held liable for criminal contempt. The Purcell Envelope Company had violated an injunction issued by a district court that prohibited it from engaging in certain business practices deemed anti-competitive under the Sherman Antitrust Act. When brought to trial, the company argued that as a corporate entity, it was incapable of forming intent and thus couldn't be found guilty of contempt. However, this argument was rejected by both lower courts and eventually by the Supreme Court itself which upheld their decisions. The high court stated that corporations are capable of committing wrongful acts through their agents or representatives and can therefore be held accountable for such actions including contemptuous conduct towards judicial orders or decrees. This ruling established important legal precedent regarding corporate liability for criminal behavior.

In the dissenting opinion for United States v. Purcell Envelope Company, it was argued that the Sherman Act should not be applied to labor unions because they are not commercial organizations and their activities do not constitute trade or commerce in a traditional sense. The dissenting justices believed that applying antitrust laws to labor unions would infringe upon workers' rights to organize and collectively bargain, which are fundamental principles of American democracy. They also expressed concern about the potential misuse of antitrust laws by powerful business interests against vulnerable workers. Furthermore, they disagreed with the majority's interpretation of "restraint of trade," arguing that this term should only apply to monopolistic practices aimed at controlling market prices or supply, rather than collective bargaining activities by labor unions.