140 Strong—The Legal Status of Trusts. 
tained. The usual effect of an adverse decision has been simply 
a change in the form of the trust. The Chicago Gas Trust was 
soon metamorphosed, and the same is true of the Sugar Trust. 
It will be recalled that the suit by the State of New York 
against one of the companies included in the Sugar Trust re¬ 
sulted in a sweeping victory in the lower courts and a judgment 
in the higher that the trust was illegal, and could not lawfully 
transact its business in the state. To carry out the provisions 
of this decision, the North River Sugar Refining Company was 
accordingly placed in the hands of receivers, but in a short time 
the property was returned to the owners by due process of law. 
Immediately the trust was reorganized as a corporation under 
the laws of the State of New Jersey, and as a foreign corpora¬ 
tion continued to carry on its business with precisely the same 
force and effect as it formerly did as the Sugar Refineries Com¬ 
pany. In spite of all decisions trusts were not only not de¬ 
stroyed, but new ones were constantly being formed. 
With such results staring them in the face it is not surpris¬ 
ing that there arose among the people a general demand for 
state and federal legislation. The New York legislature which 
had failed to pass the anti-trust bills introduced in 1888 and 
1889, enacted a law in the following year. In 1889, laws de¬ 
fining and prohibiting trusts, and providing for the punishment 
of violations of the law, were passed in Missouri, Texas, North 
Carolina, Nebraska and Kansas; in 1890 by New York, Missis¬ 
sippi, Iowa and Congress; and in 1891 by Illinois, Alabama, 
Tennessee and Georgia. It was during these years that the 
popular agitation reached its highest point and found expression 
in a great body of trust literature, newspaper criticism, party 
platforms (twenty-three states in 1890). 
Passing now from the status of trust combinations at com¬ 
mon law to the consideration of some of the recent legislation 
directed against them, we will examine first the Act of Con¬ 
gress, approved July 2, 1890 (26 Statutes at Large, page 209, 
Ch. 647). The trust question was called to the attention of 
Congress by President Harrison in his message of November, 
1889, and his views voice the public sentiment and legislative 
policy of the time. “Earnest attention should be given by Con- 
