"After a round of litigation through the Iowa courts, the plaintiff chiropractors maintained one antitrust claim: they alleged that Wellmark combined or conspired with self-insured plans and out-of-state BCBS entities to price fix by establishing a maximum price for services of Iowa chiropractors in violation of the Iowa Competition Act's corollary to Section 1 of the Federal Sherman Antitrust Act.... The key to a per se theory, however, is to convince the court that the conduct falls into the unique category of agreements that can have no procompetitive value whatsoever. And in this case, the Iowa chiropractors failed to reach that bar. The Iowa Supreme Court held that Wellmark's arrangements are not 'naked price-fixing arrangements but are more akin to joint ventures.' " [Mueller v. Wellmark, Inc., No. 13-1872 (Iowa Feb. 27, 2015)]