The case of Federal Trade Commission v. Indiana Federation of Dentists in 1985 revolved around the question of whether a group of dentists violated antitrust laws by agreeing not to provide x-rays to dental insurers for use in determining benefit levels. The Indiana Federation of Dentists, a professional organization, had adopted a policy that its members would withhold such x-rays on the grounds that they were insufficient for making diagnostic decisions and could lead to substandard care if relied upon by insurance companies. However, the Federal Trade Commission (FTC) argued this was an unlawful restraint on trade because it prevented insurers from obtaining information necessary for cost-effective operation. The Supreme Court ruled in favor of FTC, stating that any agreement among competitors with potential adverse effects on competition is subject to scrutiny under antitrust law regardless if it involves price-fixing or not.

In the dissenting opinion for Federal Trade Commission v. Indiana Federation of Dentists, Justice O'Connor disagreed with the majority's view that the federation's policy constituted a restraint on trade. She argued that there was no evidence to suggest that this policy had an adverse effect on competition or consumer choice in dental services market. The justice believed it was not within FTC’s jurisdiction to determine what constitutes as ethical behavior among professionals and criticized its attempt at doing so by labeling such conduct as anti-competitive without substantial proof of harm to competition or consumers. Furthermore, she pointed out that other professional organizations have similar policies regarding withholding x-rays from insurance companies and these are not considered anticompetitive practices.