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Keywords

lawsuitattorneyliabilityappealtrustantitrustrespondent

trustantitrustdivorcerespondent

Related Cases

Hoover v. Ronwin, 466 U.S. 558, 104 S.Ct. 1989, 80 L.Ed.2d 590, 1984-1 Trade Cases P 65,980

Facts

Respondent Ronwin was denied admission to the Arizona Bar in 1974 after failing the bar examination. He alleged that the Committee on Examinations and Admissions conspired to reduce the number of competing attorneys by manipulating the grading scale. The Arizona Supreme Court had the ultimate authority over admissions, and Ronwin's petitions for review were denied. He subsequently filed a lawsuit in federal court against the Committee members, claiming violations of the Sherman Act.

Respondent Ronwin was an unsuccessful candidate for admission to the Arizona Bar in 1974. Pursuant to the Arizona Constitution, the Arizona Supreme Court has plenary authority to determine admissions to the bar.

Issue

Whether the state-action doctrine of immunity from actions under the Sherman Act applies to the grading of bar examinations by the Committee appointed by the Arizona Supreme Court.

This case presents the question whether the state-action doctrine of immunity from actions under the Sherman Act applies to the grading of bar examinations by the Committee appointed by, and according to the Rules of, the Arizona Supreme Court.

Rule

When a state legislature or supreme court acts in a legislative capacity, its actions are exempt from antitrust laws under the state-action doctrine established in Parker v. Brown.

Under Parker, when a state legislature adopts legislation, its actions constitute those of the State and ipso facto are exempt from the operation of the antitrust laws.

Analysis

The Supreme Court determined that the actions of the Committee regarding the bar examination grading formula were inseparable from the Arizona Supreme Court's exercise of its sovereign powers. Although the Committee administered the admissions process, the court retained ultimate authority over admissions, making the Committee's actions effectively those of the court itself, and thus exempt from Sherman Act liability.

In this case, the actions of the Committee with regard to the bar examination grading formula cannot be divorced from the Arizona Supreme Court's exercise of its sovereign powers.

Conclusion

The Supreme Court reversed the Court of Appeals' decision, affirming that the District Court properly dismissed Ronwin's complaint for failure to state a claim.

We conclude that the District Court properly dismissed Ronwin's complaint for failure to state a claim upon which relief can be granted.

Who won?

The Arizona Supreme Court prevailed because the Supreme Court found that the actions of the Committee were state actions exempt from antitrust laws.

The Supreme Court held that action of the Committee was action of the Arizona Supreme Court and thus was state action exempt from the antitrust laws.

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