Page:Earle, Liberty to Trade as Buttressed by National Law, 1909 22.jpg

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be expected. Then it is perfectly proper to say, as the Earl of Halsbury, L. C., does in South Wales Miners' Federation vs. Glamorgan:[1]

"It is, further, a principle of the law, applicable even to the criminal law, that people are presumed to intend the reasonable consequences of their acts." Indeed, this presumption is so absolutely necessary that the Supreme Court has had to apply it even to the enactments of the sovereign States themselves, so interpreting their statutory acts, no matter how they themselves assert their purposes. "In whatever language a statute may be framed, its purpose must be determined by its natural and reasonable effects. * * * The motives of the legislators, considered as the purposes they had in view, will always be presumed to be to accomplish that which follows as the natural and reasonable effect of their enactments."[2] And, in such a case, it is equally accurate to say intent is immaterial; but this may well mislead, and has often misled where proof of intent becomes essential, as it sometimes really does in these cases.

This is best illustrated by the cases themselves. Mr. Justice Peckham says:[3] "It is useless for the defendants to say they did not intend to regulate or affect interstate commerce. They intended to make the very combination and agreement which they in fact did make, and they must be held to have intended (if in such case intention is of the least importance) the necessary and direct result of their agreement."

So Mr. Justice Harlan says in the Securities case:[4] "Is the motive with which a forbidden combination or


  1. 1905, A. C. 244 (1905).
  2. Mr Justice Harlan, Minnesota vs Barber, 136 U. S 321 (1890).
  3. Addyston Case, 175 U. S. 243 (1899).
  4. 193 U S 328 (1904).

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