In the case of United States v. Universal C.I.T. Credit Corporation et al., 1952, the U.S Supreme Court ruled that a company could be held liable for violating antitrust laws even if it did not have explicit knowledge of its actions' illegality. The court found Universal C.I.T Credit Corporation guilty of conspiring to monopolize trade and commerce in violation of Section 1 and 2 of the Sherman Act by controlling retail installment financing in certain areas through exclusive contracts with appliance manufacturers and dealerships. The corporation argued they were unaware their conduct was illegal, but Justice Frankfurter stated ignorance does not excuse liability under these statutes because they are designed to prevent economic harm rather than punish moral wrongdoing.

In the dissenting opinion for United States v. Universal C.I.T. Credit Corporation et al., Justice Jackson disagreed with the majority's interpretation of Section 1 of the Sherman Act, arguing that it was too broad and could potentially criminalize normal business practices. He contended that there should be a clear distinction between price fixing, which is illegal per se under the Act, and other types of agreements among competitors that may have legitimate purposes or effects. According to him, not all agreements among competitors are inherently anti-competitive or harmful to consumers; some can actually promote competition or benefit consumers in certain circumstances. Therefore, he believed that such agreements should not automatically be presumed illegal without considering their actual purpose or effect on competition and consumer welfare.