Federal Trade Commission v. Indiana Federation of Dentists
Supreme Court
476 U.S. 447 (1986)
The Indiana Federation of Dentists (defendant), a group formed by Indiana dentists in 1976, adopted a policy of collectively refusing to provide patient X-rays to dental-insurance companies that used the X-rays to determine the cheapest adequate treatment, viewing insurer cost review as a threat to dentists' professional autonomy and income. The FTC (plaintiff) found the collective refusal eliminated competition among the Federation's member dentists over how to deal with insurers and constituted an unreasonable restraint of trade under the Sherman Act; the court of appeals reversed, and the FTC appealed.
Whether a professional association's collective agreement to withhold cost-relevant information from insurers is an antitrust violation when the agreement reduces competition among the association's own members, even without a formal market analysis.