A federal judge has dismissed a proposed antitrust class action accusing a group of hospitals and health systems, the American Society of Health-System Pharmacists and a residency matching organization of conspiring to suppress pharmacy residents’ pay, according to an Aug. 12 ruling.
Judge Deborah Boardman of the U.S. District Court for the District of Maryland dismissed the case without prejudice; the former residents who brought it have until Sept. 11 to file an amended complaint. If they do not, the case will be closed.
The residents — Alexis Albert, May Ann Hudgins, June Kim and Meaghan Walker — alleged the defendants used the ASHP Resident Matching Program, known as the Match, to standardize and depress residents’ wages, limit their ability to move between programs and restrict the number of residency positions.
Ms. Boardman found the residents did not plausibly allege the hospitals agreed with one another to do so. At most, she wrote, they described a “rimless wheel” — a series of separate agreements between each employer and the ASHP, rather than a horizontal conspiracy among competitors. Because an agreement is required for both counts, both were dismissed.
The second count, which centered on the exchange of salary data through the ASHP’s publicly available Residency Directory, was also dismissed. Ms. Boardman said the residents failed to allege an unreasonable restraint of trade because that information is public.
Not every defense argument succeeded. The judge rejected the hospitals’ immunity claims and concluded the residents had plausibly defined a relevant labor market and would have legal standing to sue if they fix the other defects in their complaint. Separately, she dismissed the claims against National Matching Services, the Canada-based company that administers the Match, and a University of California Health executive named as a defendant, finding the court lacked personal jurisdiction over them.
The lawsuit was first filed in February 2025 and later consolidated with related cases. The complaint named 17 hospital and health system employers as defendants, along with the ASHP and National Matching Services.
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