In the United States v. Reynolds case of 1914, the Supreme Court addressed whether a federal law prohibiting polygamy was unconstitutional as it infringed upon religious freedoms. The defendant, George Reynolds, was a member of The Church of Jesus Christ of Latter-day Saints (LDS Church), which at that time allowed and encouraged its male members to practice polygamy. He argued that this law violated his First Amendment rights to freely exercise his religion. However, the court ruled against him stating that while beliefs are protected by the Constitution, illegal actions are not - even if they're done in name of religion. Therefore, laws banning practices like polygamy were deemed constitutional because they regulated actions rather than beliefs or opinions.

In the dissenting opinion for United States v. Reynolds, Justice Holmes disagreed with the majority's interpretation of the Sherman Act and its application in this case. He argued that a monopoly is not inherently illegal under the act unless it involves an unreasonable restraint on trade or commerce among several states. In his view, there was no evidence to suggest that Reynolds' exclusive control over tobacco stemmed from any such restraint; instead, he believed it resulted from superior skill and economic foresight. Therefore, he concluded that punishing successful business practices would discourage competition rather than promote it as intended by antitrust laws like the Sherman Act. Furthermore, Holmes criticized what he saw as an overly broad reading of "restraint of trade," arguing that almost every contract could be seen as restraining trade in some way if interpreted too loosely.