Wilk v. American Medical Association case brief

Wilk v. American Medical Association case brief summary
895 F.2d 352 (1990)

CASE SYNOPSIS

Defendant medical trade association appealed the judgment of the United States District Court for the Northern District of Illinois, Eastern Division, finding defendant liable for violating§ 1 of the Sherman Act, 15 U.S.C.S. § 1, and granting injunctive relief under § 16 of the Clayton Act, 15 U.S.C.S. § 26.

CASE FACTS
Plaintiff chiropractors filed an action against defendant medical trade association and various other medical organizations and professionals, charging them with violating §§ 1 and 2 of the Sherman Act, 15 U.S.C.S. §§ 1 and 2. Plaintiffs contended that defendant had conspired with the other medical organizations and professionals to eliminate the chiropractic profession by refusing to deal with plaintiffs and the other chiropractors. It was alleged that defendant accomplished this conspiracy by labeling plaintiffs as unscientific practitioners, and then encouraging others, through its ethical guidelines, not to associate with them and to boycott any person labeled a chiropractor.

DISCUSSION

• The district court found that under the Sherman Act's rule of reason, plaintiffs had established that defendant's boycott was illegal and it ordered injunctive relief. 
• The court affirmed, holding that the facts properly supported the district court's findings and that the grant of injunctive relief was a proper remedy.

CONCLUSION

The court affirmed the district court's findings and the grant of injunctive relief where defendant medical association violated the federal antitrust statutes in conspiring to eliminate plaintiff chiropractors' profession through encouraging boycott of plaintiff chiropractors.

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