Dental Examiners Case Study

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The United Supreme Court, in Dental Examiners, held that the Dental Board did not have immunity from antitrust laws because it was not actively supervised. Dental Examiners involved two major United State Supreme Court holdings. The first holding is that state boards, controlled by market participants, have to meet both prongs of the Midcal Test. The second holding is that state boards that do not meet both Midcal prongs can be subject to antitrust lawsuits. State Boards Must Meet Both Prongs of the Midcal Test The biggest outcome of Dental Examiners was the United States Court’s holding that state boards must meet both prongs of the Midcal test. The Court first rejected the Dental Board’s argument that it exercised sovereign power because …show more content…

Dental Examiners did not hold that state boards did not have immunity from antitrust lawsuits, instead the decision increased the requirements on state boards for them to show that they have immunity. That said if state boards are unable to show they meet the requirements for immunity, then they do face the risk of antitrust liability. The rest of this memorandum will discuss the practical implications of Dental Examiners and how the decision will likely effect state boards. Guidance from the Federal Trade …show more content…

Some scholars, such as Professor Aaron Edlin and Professor Rebecca Haw Allensworth, have predicted that Dental Examiners will cause a fury storm of lawsuits against state boards. These predictions have largely come true with antitrust suits being filed across the United States. For example, antitrust lawsuits have been filed against state boards in Virginia, Tennessee, Missouri, Louisiana, Connecticut, Georgia, Ohio, Pennsylvania, and North Carolina. These lawsuits can provide valuable information on how Dental Examiners may be enforced in the courts, but as a warning it is unclear whether these lawsuits have merit or whether they will be successful. With that in mind, what can we learn from these

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