421 U.S. 773 (1975)
Goldfarb v. Virginia State Bar is a foundational Supreme Court decision at the intersection of antitrust law and professional regulation.
Does the Sherman Act apply to the practice of law so as to render a bar association minimum fee schedule for legal services per se unlawful price fixing, and, if so, are the bar association and the state bar immune from antitrust liability under the state action doctrine?
Section 1 of the Sherman Act prohibits contracts, combinations, or conspiracies in restraint of trade or commerce among the several States. Agreements among competitors to fix prices are per se unlawful under § 1. The Act applies to professional services, including the practice of law, where the challenged conduct occurs in or substantially affects interstate commerce. Under the state action (Parker) doctrine, antitrust immunity attaches only when the restraint is the result of the State acting as sovereign—i.e., when the anticompetitive conduct is compelled by a clearly articulated state policy; mere authorization, approval, or acquiescence by a professional body is insufficient.
Yes. The minimum fee schedule for legal services constituted per se unlawful price fixing under § 1 of the Sherman Act, the practice of law falls within "trade or commerce" for antitrust purposes when it affects interstate commerce, and the defendants were not immune under the state action doctrine because the restraint was not compelled by the State acting as sovereign.
Goldfarb eliminated any broad "learned profession" exception to the Sherman Act and confirmed that lawyers and their associations are subject to per se antitrust rules against price fixing. The decision also became a cornerstone in the development of state action doctrine as applied to professional regulation, anticipating later clarifications that immunity requires a clearly articulated state policy and, where private actors are involved, active state supervision. For students, the case is essential to understanding how antitrust principles constrain professional self-regulation and how federal competition law reaches local conduct with interstate effects.