Bartholomew v. Virginia Chiropractors Association, Inc.
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
The Fourth Circuit expressly recognized the partial overruling in Ratino v. Medical Service of the District of Columbia. Bartholomew's separate Clayton Act venue ruling was unaffected. All 41 flagged citations were read; the confirmed treatment is listed below.
41 later cases cite Bartholomew v. Virginia Chiropractors Association, Inc.; 41 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Bartholomew v. Virginia Chiropractors Association, Inc.?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Overruled in part
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The Supreme Court's ruling that chiropractic peer review is outside the McCarran–Ferguson antitrust exemption displaced Bartholomew's contrary holding about that practice.
Union Labor Life Insurance Co. v. Pireno · Supreme Court of the United States · filed
In sum, we conclude that ULL’s use of NYSCA s Peer Review Committee does not constitute the “business of insurance” within the meaning of § 2(b) of the McCarran-Ferguson Act. ... As noted by the Court of Appeals, id., at 395, n. 13, the decision below is contrary to that of the Court of Appeals for the Fourth Circuit “in a factually identical ease.” See Bartholomew v. Virginia Chiropractors Assn., 612 F. 2d 812 (1979).
Read the full opinion on CourtListener →
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