FEE SCHEDULES AND THE SHERMAN ANTITRUST ACT

Price fixing, as it relates to commodities and articles of trade, has been declared by the United States Supreme Court to be an unreasonable restraint of trade and illegal within the meaning of the Sherman Antitrust Act. In a recent case decided by the district court for the District of Columbia the government contended for the first time that the adoption of fee schedules applicable to the delivery of personal services is likewise proscribed by the federal law. The Washington Real Estate Board had for many years, as had other associations of brokers, prescribed rates of commissions for brokers' services, and prior to this case the government had never contended that such activity violated the Sherman Antitrust Act. The Washington Board and its individual members, however, were alleged to have "combined to fix real estate brokerage commissions" in an unlawful manner. The National Association of Real Estate Boards was also