United States v. Aluminum Co. of America (Alcoa)
148 F.2d 416 (1945)
Alcoa, a US company, was
engaged in an international cartel with several Canadian and European
aluminum producers to monopolize the aluminum market.
The US government sued Alcoa
under the Sherman Anti-Trust Act.
Alcoa argued that most of
the cartel's activities took place outside the US, and therefore, were
beyond the reach of US jurisdiction.
The Appellate Court found that
Alcoa had violated the Sherman Anti-Trust Act.
The Appellate Court found
that, "the agreements would clearly have been unlawful, had they
been made within the United States, and it follows that they were
unlawful, though made abroad, if they were intended to affect imports and
did affect them..."
This case helped to establish
the Alcoa Effects Test, which says
that US courts have jurisdiction over acts abroad, if those acts have an effect within the territorial jurisdiction of the US.
That was an expansion over
the earlier decision in American Banana Co. v. United Fruit Co. (213 U.S. 347 (1909)), which found that
jurisdiction was, for the most part, was limited to acts that occurred on