Sanjuan v. American Board of Psychiatry and Neurosurgery:
a.    Psychiatrists did not pass the oral exams and failed certification, and then sued the baord b/c dissatisfied with the board’s appeals process.  Psychiatrists claim that without certification, they will not make as much money, and get hospital privileges, etc.
b.    HELD:  Antitrust law has a purpose to protect consumers.  And psychiatrists are not consumers, but producers.  And in fact, the certification will allow the psychiatrists to increase costs.  And the idea of the certification program is to have competition to keep prices down.