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Massachusetts School of Law at Andover, Inc. v. American Bar Association
United States Court of Appeals for the Third Circuit
107 F.3d 1026 (1997)
The American Bar Association (ABA) (defendant) was a national professional association of lawyers that issued mainstream accreditation guidelines for law schools. The American Association of Law Schools (AALS) (defendant) was an organization representing the law school community. The Law School Admissions Council, Inc. (LSAC) (defendants) provided law schools with admissions services. The ABA, AALS, and LSAC were not formally affiliated with one another, but worked together to standardize and control the educational criteria for taking the bar examination in all 50 states. Through this work, the three entities exerted mainstream influence on legal-education standards. However, most states also provided alternative ways to satisfy the legal-education requirement necessary for bar admission, including petitions for exceptions by individuals and law schools. In 1994, the ABA denied accreditation to Massachusetts School of Law at Andover, Inc. (MSL) (plaintiff), citing numerous inconsistencies with ABA guidelines. MSL sued the ABA, AALS, LSAC and 22 individuals (defendants), alleging that the defendants conspired to enforce a group boycott in violation of § 1 of the Sherman Act, 15 U.S.C. § 1, when they refused to provide accreditation to MSL, which was necessary for MSL to compete with other law schools on equal footing. MSL alleged that this group refusal to deal caused harm to MSL in the form of decreased applications, reputational stigma, artificially inflated faculty salaries, and difficulty competing. The district court granted summary judgment to the defendants. MSL appealed.
Rule of Law
Holding and Reasoning (Greenberg, J.)
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