District of Columbia is facing criminal trial. Special counsel are investigating the coal combination, and special counsel are investigating the Standard Oil combination. {119} "Three of the causes won in the Supreme Court of the United States have furnished decisions of the utmost importance. In the Tobacco Trust case of Hale agt. Henkel, the Supreme Court denied the claim of the trust corporations to be exempt under the Constitution from furnishing testimony against themselves by the production of their books and papers before a federal grand jury. Thus, the protection of secrecy for corporate wrongdoing is beaten down. In the Northern Securities case the Supreme Court held that a wrong accomplished by means of incorporating in accordance with the express provision of the New Jersey statute was just as much a violation of federal law as if there had been no incorporation. Thus, the state rights defence of protection from favoring state statutes is beaten down. In the Beef Trust case the Supreme Court held that, although the business of manufacture was carried on within the limits of a single state, yet the purchase of the raw material in different states and the sale of the finished product in different states brought the business within the interstate commerce clause of the Constitution and gave the federal government authority over it. Thus, the defence that the state alone can deal with manufacturing corporations, however widespread their business, is beaten down. "The obstacles to the enforcement of the federal anti-trust act thus removed are obstacles which stood in the way of all proceedings, and they had to be cleared away before any proceedings of the same character against the same classes of corporations could be successfully maintained. They have been removed, not by newspaper headlines and denunciation, but by skill, ability, and energy of the highest order.