Arizona v. Maricopa County Medical Society, 457 U.S. 332 (1982), was aU.S. Supreme Court case involvingantitrust law. A society of doctors inMaricopa County, Arizona, established maximum fees that their members could claim for seeing patients who were covered by certain health insurance plans. Arizona charged them with violations of stateantitrust law regardingprice fixing. The society tried to rebut the state's charges by claiming that the maximum-fee arrangement was necessary to allow doctors to see these patients, and therefore generated economic benefits.
On appeal, the Supreme Court rejected this defense, saying that price fixing was not truly necessary here: the society could have used insurance to pool their risk. The society's efficiency justification was either a pretext, or else could have been done through less restrictive means. The Court held that their justifications failed as a matter of fact.
Maricopa County Medical Society, by agreement of their member doctors, established the maximum fees the doctors may claim in full payment for health services provided to policyholders of specifiedinsurance plans.Arizona filed a complaint against MCMS inFederal District Court, alleging that they were engaged in an illegalprice-fixing conspiracy in violation of theSherman Antitrust Act.
The ruling stipulates not just that maximum price fixing among competitors is unlawful, but that it is unlawful per se. This precludes any significant inquiry into potential procompetitive justifications for such an arrangement. According to one author, the result of the decision was to make "antitrust analysis once again confused and haphazard."[1]
Leffler, Keith B. (1983), "Arizona v. Maricopa County Medical Society: Maximum-Price Agreements in Markets with Insured Buyers",Supreme Court Economic Review,2:187–211,doi:10.1086/scer.2.1147125,S2CID155736979.
