United States v. W. T. Grant Co., 345 U.S. 629 (1953) (U.S. Supreme Court)
United States v. W.
Does voluntary cessation of allegedly unlawful interlocking directorates moot the government's antitrust enforcement action, and if not, what standard governs whether an injunction should issue after the conduct has ceased?
Voluntary cessation of allegedly illegal conduct does not, by itself, render a case moot; the defendant bears a "heavy burden" of persuading the court that the challenged conduct cannot reasonably be expected to recur. As to injunctive relief, the "sole function" of an injunction is to forestall future violations; thus, where the challenged conduct has ceased, an injunction may issue only upon a showing of a "cognizable danger of recurrent violation"—something more than a mere possibility—assessed within the district court's equitable discretion.
The controversy was not mooted by the defendants' voluntary termination of the interlocks. The proper inquiry for prospective relief is whether there exists a cognizable danger that the violations will recur. The case was remanded for the district court to apply this standard and exercise its equitable discretion accordingly.
W. T. Grant is a staple in both antitrust and federal courts curricula. It supplies the canonical articulation of the voluntary cessation doctrine used across subject matters—from antitrust to environmental law and First Amendment litigation—ensuring courts retain power to adjudicate disputes despite strategic halts in challenged behavior. It also provides the enduring standard for post-cessation injunctive relief: the government (or any plaintiff) must show a "cognizable danger of recurrent violation," with the decision committed to the trial court's equitable discretion. For law students, the case illustrates how justiciability doctrines structure remedies and how prophylactic antitrust provisions are enforced through forward-looking equitable standards.