In the 1981 case of American Medical Association et al. v. Federal Trade Commission, the U.S Supreme Court ruled in favor of the Federal Trade Commission (FTC). The FTC had issued an order prohibiting the American Medical Association (AMA) from restricting its members' ability to advertise their services, arguing that such restrictions constituted anti-competitive behavior under federal antitrust laws. The AMA challenged this order, asserting that it was outside of FTC's jurisdiction because medical practice is a profession and not trade or commerce which falls within FTC's purview. However, the Supreme Court upheld FTC’s authority over professions like medicine and found AMA’s advertising restrictions as limiting competition among physicians thus violating antitrust laws.

In the dissenting opinion for American Medical Association et al. v. Federal Trade Commission, Justice Powell argued that the majority's decision to allow the FTC jurisdiction over non-profit professional organizations was a misinterpretation of legislative intent and an overreach of authority. He contended that Congress did not intend for such groups to be subject to FTC regulation when it enacted the Federal Trade Commission Act in 1914, as they are neither corporations nor unincorporated associations existing for profit. Furthermore, he expressed concern about potential negative impacts on other non-profit entities if this ruling were applied broadly. This could result in undue federal interference with state-regulated professions and potentially chill innovation within these fields due to fear of regulatory scrutiny.