Supreme Court of the United States
California Dental Association v. Federal Trade Commission
May 24, 1999526 U.S. 756
Summary
The Court held that the FTC has jurisdiction over the California Dental Association because it provides substantial economic benefits to its for‑profit members, and vacated the Ninth Circuit’s judgment that a quick‑look rule‑of‑reason analysis was sufficient, remanding for a fuller rule‑of‑reason inquiry. The Court emphasized that the anticompetitive effects of the CDA’s advertising restrictions were not obvious enough to justify abbreviated review. Justice Breyer, joined by Justices Stevens, Kennedy and Ginsburg, concurred in part and dissented in part, arguing that the Commission’s findings were supported by substantial evidence.
Holding
- Whether the FTC has jurisdiction over the CDA.. The Commission’s jurisdiction under the FTC Act extends to an association that provides substantial economic benefit to its for‑profit members.
- Whether a quick‑look rule‑of‑reason analysis suffices for the CDA’s advertising restrictions.. The Ninth Circuit erred in concluding that a quick‑look analysis was appropriate; the case must be remanded for a more thorough rule‑of‑reason analysis.
Docket 97-1625