Upon its development some critics of "Standard Oil", including the lone dissenter Justice John Marshall Harlan, argued that "Standard Oil" and its rule of reason were a departure from previous Sherman Act case law, which purportedly had interpreted the language of the Sherman Act to hold that all contracts restraining trade were prohibited, regardless of whether the restraint actually produced ill effects. These critics emphasized in particular the Court's decision in "United States v. Trans-Missouri Freight Association", 166 U.S. 290 (1897), which contains some language suggesting that a mere restriction on the autonomy of traders would suffice to establish that an agreement restrained trade within the meaning of the Act.