Simons called for the courts to spurn the rule of reason because “[when] lawyers try to draw a line between lawful and unlawful restraint of trade, they invariably end up with something that looks like the silhouette of a roller-coaster. . . . The purpose may be laudable; but the result is that few people get caught, rather fortuitously, and the growth of monopoly, with perhaps some formal modification, proceeds apace” (101).

Philip Mirowski & Dieter Plehwe (eds.), The Road from Mont Pèlerin, loc. 1194