Chiropractic Antitrust Suit: Index

In 1976, a series of lawsuits was begun against the AMA, other professional organizations, and several individual critics, charging that they had conspired to destroy chiropractic and to illegally deprive chiropractors of access to laboratory, x-ray, and hospital facilities. Most of the defendant groups agreed in out-of-court settlements that their physician members were free to decide for themselves how to deal with chiropractors.

The American Medical Association (AMA), the American College of Radiology (ACOR), the American Academy of Orthopedic Surgery (AAOS), seven other groups, and four individual defendants chose to defend in court. In January 1981, after an 8-week trial, the jury ruled unanimously in their favor. However, the case was reversed on appeal and the parties agreed to retry it in front of a judge rather than a jury.

In 1987, federal court judge Susan Getzendanner concluded that during the 1960s “there was a lot of material available to the AMA Committee on Quackery that supported its belief that all chiropractic was unscientific and deleterious.” The judge also noted that chiropractors still took too many x-rays. However, she ruled that the AMA had engaged in an illegal boycott. She concluded that the dominant reason for the AMA’s antichiropractic campaign was the belief that chiropractic was not in the best interest of patients. But she ruled that this did not justify attempting to contain and eliminate an entire licensed profession without first demonstrating that a less restrictive campaign could not succeed in protecting the public. Although chiropractors trumpet the antitrust ruling as an endorsement of their effectiveness, the case was decided on narrow legal grounds (restraint of trade) and was not an evaluation of chiropractic methods.

First Trial

• Original Complaint, October 12, 1976
• Trial Documents
  • Opening Argument by ACOR
  • Selected Exhibits
    • Sherman Ciollege of Straight Chiropractic Publications
    • Chiropractors: Healers or Quacks? (Consumer Reports)
    • Logan Basic Method (Excerpts)
    • A Dozen Easy Ways to Double Your Income with Clinic Masters
    • Why the Chiropractor Should Spinograph Every Case
    • ICA Newsletter: Chiropractors Battle Immunization Laws
    • Newspaper Ads Offering Fee Spinal X-Rays (Pennsylvania, 1971)
  • Excerpts of Testimony
  • Closing Arguments by ACOR, AAOS, and AMA
• Reversal by U.S. Court of Appeals, September 19, 1983

Second Trial

• Summary of Opinion and Order
• Summary of Injunction Issued September 25, 1987
• Memorandum Opinion and Order
  • I. The First Trial and the Wilk Decision
  • II. Summary of This Court’s Rulings
  • III. New Zealand Report
  • IV. A. Liability of the American Medical Association (AMA) and Dr. Sammons
    • 1. Boycott Activities
    • 2. Unreasonable Restraint of Trade
    • 3. Antitrust Injury
    • 4. Rejection of Per Se Violation
    • 5. Patient Care Defense
    • 6. Entitlement to an Injunction
  • B. Liability of Remaining Defendants
    • 1. General Legal Principles Applicable to Co-Conspirators
    • 2. Joint Commission on Accreditation of Hospitals (JCAH)
    • 3. American College of Physicians (ACP)
    • 4. American Academy of Orthopaedic Surgeons (AAOS)
    • 5. American College of Surgeons (ACS)
    • 6. American College of Radiology (ACR)
• Permanent Injunction Order 
• U.S. Court of Appeals ruling, February 7, 1990