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 US territory.