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), American Association of Law Schools (AALS), and Law School Admissions Council (LSAC) (defendants) — though not formally affiliated — worked together to set mainstream accreditation and admissions standards effectively controlling legal education nationwide. When the ABA denied accreditation to Massachusetts School of Law at Andover (MSL) (plaintiff) in 1994, citing inconsistencies with its guidelines, MSL sued the ABA, AALS, LSAC, and various individuals, alleging a Sherman Act group boycott that caused decreased applications, reputational harm, artificially inflated faculty salaries, and competitive disadvantage. The district court granted the defendants summary judgment, and MSL appealed.
Whether a professional organization violates the Sherman Act by promulgating educational accreditation standards and seeking governmental adoption of those standards.