American Medical Asociation (AMA) engaged in a conspiracy to eliminate the chiropractic profession
n 1963 the AMA formed its Committee on Quackery („Committee“). The Committee worked diligently to eliminate chiropractic. A primary method to achieve this goal was to make it unethical for medical physicians to professionally associate with chiropractors. Under former Principle 3, it was unethical for medical physicians to associate with „unscientific practitioners.“ In 1966, the AMA’s House of Delegates passed a resolution labelling chiropractic an unscientific cult….The district court found the AMA’s purpose in all of this was to prevent medical physicians from referring patients to chiropractors and from accepting referrals of patients from chiropractors, so as to prevent chiropractors from obtaining access to hospital diagnostic services and membership on hospital medical staffs, to prevent medical physicians from teaching at chiropractic colleges or engaging in any joint research, and to prevent any cooperation between the two groups in the delivery of health care services. Despite the Committee’s efforts, chiropractic ultimately became licensed in all 50 states….Based on these findings, the court held that the AMA and its members violated § 1 of the Sherman Act by unlawfully conspiring to restrain trade. According to the court, the AMA’s boycott’s purpose had been to eliminate chiropractic; the boycott had substantial anticompetitive effects; the boycott had no counterbalancing pro-competitive effects; and the AMA’s unlawful conduct injured the plaintiffs…..Indeed, the court found that the AMA intended to „destroy a competitor,“ namely, chiropractors,, In sum, we agree with the district court that the AMA’s boycott constituted an unreasonable restraint of trade under § 1 of the Sherman Act under the rule of reason. Therefore, the district court’s findings that the AMA’s boycott was anticompetitive, and was not counter-balanced by any pro-competitive effects were not erroneous.