A Match Made in Antitrust Heaven? A Liberalistic Exploration of the Medical Match's Antitrust Exemption


In the 2004 case Jung v. Association of American Medical Colleges, a group of resident physicians brought a class action suit challenging the legality of the National Residency Matching Program, a system that controls essentially all appointments to medical residency programs. The plaintiffs claimed the Match artificially depressed wages and created an anticompetitive labor market. The lawsuit was met with a swift end by the codification of an antitrust exemption to the Match. Although the Jung case is over, medical residents continue to face unreasonable restraints on their liberty. This note begins with an overview of medical education and the residency match process and details the Jung litigation and resulting antitrust exemption. Then, the focus shifts to a philosophical exploration of classic ideas of liberty and how the Match contradicts theories of classical liberalism and economics. Finally, the note concludes with proposed alternatives and modifications that can be implemented to improve the Match process and working conditions of medical residents.


liberalism, law and medicine, antitrust



Melissa Mayeux (Notes Editor, Washington University Jurisprudence Review; J.D. Candidate, Washington University School of Law, Class of 2021)



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