. In regard to antitrust decrees, the first consent decree used in antitrust regulation under the Sherman Antitrust Act was Swift & Co. v. United States.. With Swift & Co. v. United States, the Supreme Court ruled that a consent decree could be modified or terminated only when new developments over time bring out a "grievous wrong" in how the ruling of the consent decree affects the parties of the suit. The Supreme Court supported this limited flexibility of consent decrees in United States v. Terminal Railroad Association: "[A] decree will not be expanded by implication or intendment beyond the meaning of its terms when read in the light of the issues and the purposes for which the suit was brought.".
