outspoken criticism of the antitrust regime. Another conservative legal scholar and judge, Richard Posner of the Seventh Circuit, does not condemn the entire regime, but expresses concern with the potential that it could be applied to create inefficiency, rather than to avoid inefficiency. Posner further believes, along with a number of others, including Bork, that genuinely inefficient cartels and coercive monopolies, the target of the act, would be self-corrected by market forces, making the strict penalties of antitrust legislation unnecessary. Conversely, liberal U.S. Supreme Court Justice William O. Douglas criticized the judiciary for interpreting and enforcing the antitrust law unequally: "From the beginning it [the Sherman Act] has been applied by judges hostile to its purposes, friendly to the empire builders who wanted it emasculated... trusts that were dissolved reintegrated in new forms... It is ironic that the Sherman Act was truly effective in only one respect, and that was when it was applied to labor unions. Then the courts read it with a literalness that never appeared in their other decisions." According to a 2018 study in the journal Public Choice, "Senator John Sherman of Ohio was motivated to introduce an antitrust bill in late 1889 partly as a way of enacting revenge on his political rival, General and former Governor Russell Alger of Michigan, because Sherman believed that Alger personally had cost him the presidential nomination at the 1888 Republican national convention... Sherman was able to pursue his revenge motive by combining it with the broader Republican goals of preserving high tariffs and attacking the trusts." See also Alcoa American Bar Association American Tobacco Company Antitrust Bell System divestiture Cartel Clayton Antitrust Act of 1914 DRAM price fixing George H. Earle, Jr. Plan of Bill Proposed by Hon. George H. Earle, Jr., Philadelphia. (1911) at Wikisource Federal Baseball Club v. National League Laissez-faire Lysine price-fixing conspiracy Monsanto Co. v. Spray-Rite Service Corp. National Linseed Oil Trust Northern Securities Company Price fixing Resale price maintenance Sarbanes–Oxley Act Standard Oil Standard Oil Co. of New Jersey v. United States Ticketmaster Tying (commerce) United States v. Microsoft Notes and references External links Official websites U.S. Department of Justice: Antitrust Division U.S. Department of Justice: Antitrust Division – text of SHERMAN ANTITRUST ACT, 15 U.S.C. §§ 1–7 Additional information Antitrust Division's "Corporate Leniency Policy" Antitrust by Alan Greenspan "Labor and the Sherman Act" (1940). Yale Law Journal 49(3) p. 518. . Dr.