Ronwin was an unsuccessful candidate for admission to the Arizona State Bar. Under Arizona Supreme Court rules, a Committee on Examinations and Admissions appointed by the court was authorized to...



Ronwin was an unsuccessful candidate for admission to the Arizona State Bar. Under Arizona Supreme Court rules, a Committee on Examinations and Admissions appointed by the court was authorized to examine the applicants on specified subjects, to grade the examinations according to a formula submitted to the court before the examination, and then to submit its recommendations to the court. A rejected applicant could seek review of the state supreme court’s decision. After he was rejected by both the committee and the state supreme court, Ronwin appealed to the U.S. Supreme Court, claiming that the committee had violated Section 1 of the Sherman Act by artificially reducing the number of attorneys in the state. He argued that the committee had set the grading scale with reference to the number of new attorneys it thought was desirable in Arizona, as opposed to a “suitable”level of competence. The defendants argued that they were immune from antitrust liability under the act-of-state doctrine. Who won this case and why?



May 02, 2022
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