Missouri Law Review Volume 41 Issue 1 Winter 1976 Article 6 Winter 1976 Goldfarb v. Virginia State Bar: The Professions Are Subject to the Sherman Act Richard B. Tyler Follow this and additional works at: https://scholarship.law.missouri.edu/mlr Part of the Law Commons Recommended Citation Richard B. Tyler, Goldfarb v. Virginia State Bar: The Professions Are Subject to the Sherman Act, 41 MO. L. REV. (1976) Available at: https://scholarship.law.missouri.edu/mlr/vol41/iss1/6 This Article is brought to you for free and open access by the Law Journals at University of Missouri School of Law Scholarship Repository. It has been accepted for inclusion in Missouri Law Review by an authorized editor of University of Missouri School of Law Scholarship Repository. For more information, please contact
[email protected]. Tyler: Tyler: Goldfarb v. Virginia State Bar: MISSOURI LAW REVIEW Volume 41 Winter 1976 Number 1 GOLDFARB V. VIRGINIA STATE BAR: THE PROFESSIONS ARE SUBJECT TO THE SHERMAN ACT Richard B. Tyler* I. INTRODUCTION "The nature of an occupation, standing alone, does not provide sanctuary from the Sherman Act ... nor is the public service aspect of professional practice controlling in determining whether § 1 includes professions. ..." With these words, the United States Supreme Court established the applicability of the Sherman Act 2 to the "learned pro- fessions." The import of the Court's holding has not been lost on the anti- trust enforcement agencies. They have recently filed suit or announced in- vestigations of the activities of other professional organizations.3 Some professionals, on the other hand, have attempted to read the decision OAsst.