The Supreme Court recently affirmed the Federal Trade Commission and the 4th Circuit in North Carolina State Board of Dental Examiners v FTC.  While at the FTC, Antitrust Partner Rick Dagen was lead trial counsel in the matter and second chaired the 4th Circuit argument. The Court held that state boards controlled by financially-interested market participants (here, dentists elected by dentists) require some supervision by disinterested state officials if they want antitrust immunity.