Association of Surgical Assistants v. National Board of Surgical Technology

127 F.4th 178
CourtCourt of Appeals for the Tenth Circuit
DecidedJanuary 21, 2025
Docket23-1344
StatusPublished
Cited by3 cases

This text of 127 F.4th 178 (Association of Surgical Assistants v. National Board of Surgical Technology) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Association of Surgical Assistants v. National Board of Surgical Technology, 127 F.4th 178 (10th Cir. 2025).

Opinion

Appellate Case: 23-1344 Document: 59 Date Filed: 01/21/2025 Page: 1 FILED United States Court of Appeals PUBLISH Tenth Circuit

UNITED STATES COURT OF APPEALS January 21, 2025 Christopher M. Wolpert FOR THE TENTH CIRCUIT Clerk of Court _________________________________

ASSOCIATION OF SURGICAL ASSISTANTS,

Plaintiff - Appellant,

v. No. 23-1344

NATIONAL BOARD OF SURGICAL TECHNOLOGY AND SURGICAL ASSISTING; ASSOCIATION OF SURGICAL TECHNOLOGISTS,

Defendants - Appellees. _________________________________

Appeal from the United States District Court for the District of Colorado (D.C. No. 1:22-CV-02363-MEH) _________________________________

Robert D. Lantz, Lantz Law Group, Evergreen, Colorado, for Plaintiff-Appellant.

John W. Mackay, Ray Quinney & Nebeker P.C., Salt Lake City, Utah (Brian R. Markley, Spencer Fane LLP, Overland Park, Kansas, and Jose A. Castro, Spencer Fane LLP, Denver, Colorado, with him on the brief) for Defendants-Appellees. _________________________________

Before TYMKOVICH, MATHESON, and McHUGH, Circuit Judges. _________________________________

TYMKOVICH, Circuit Judge. _________________________________

This case involves the certification process for two types of professionals who

assist surgeons in the operating room: Surgical Technologists and Surgical Assistants. Appellate Case: 23-1344 Document: 59 Date Filed: 01/21/2025 Page: 2

Technologists ensure a sterile and organized environment, while Assistants directly aid

the surgeon. Professional organizations serve each profession. The Association of

Surgical Technologists (AST) represents Technologists, and the Association of Surgical

Assistants (ASA) represents Assistants. The National Board of Surgical Technology and

Surgical Assisting (NBSTSA) is one of several certifying bodies for both Technologists

and Assistants.

Many states require Technologists and Assistants to maintain certifications to

practice their respective professions. Like other professional certifications, maintaining

these certifications requires either periodically logging enough continuing education

credits or retaking a certification exam. This lawsuit is about who can provide continuing

education services for recertifying NBSTSA certifications. To date, NBSTSA has only

authorized AST to administer continuing education services. ASA wants to join it as an

education provider.

After NBSTSA refused to authorize ASA to provide continuing education services

on its behalf, ASA sued NBSTSA and AST for antitrust violations and tortious business

interference. NBSTSA and AST moved to dismiss ASA’s Complaint. The district court

granted that motion.

We affirm. As the district court correctly explained, ASA fails to establish the

threshold requirement of an antitrust claim: the relevant market. Independently, it also

failed to plead a plausible conspiracy or valid antitrust injuries.

2 Appellate Case: 23-1344 Document: 59 Date Filed: 01/21/2025 Page: 3

I. Background

A. Surgical Assistant and Surgical Technologist – Certifications

Unless otherwise noted, we take the following material factual allegations as true

for purposes of reviewing a motion to dismiss pursuant to Fed. R. Civ. P. 12(b)(6).

Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Where noted, and as the district court before

us did, we take judicial notice of public information that is not reasonably subject to

dispute. O’Toole v. Northrop Grumman Corp., 499 F.3d 1218, 1225 (10th Cir. 2007)

(taking judicial notice of information on Northrop Grumman’s website and noting “[i]t is

not uncommon for courts to take judicial notice of factual information found on the world

wide web”).

Surgical Assistants are “advanced allied health practitioners” who aid a surgeon

with “wound closure, bleeding control, and other interoperative technical functions that

help the surgeons carry out a safe operation.” 1 Technologists, in contrast, “ensure a

sterile and organized environment.” 2 NBSTSA certifies both Assistants and

Technologists. Its certifications are called Certified Surgical First Assistant (CSFA) and

Certified Surgical Technologist (CST), respectively. To obtain either certification,

applicants must take an initial four-hour examination, and to renew a certification

1 Surgical First Assistant, MAYO CLINIC COLLEGE OF MEDICINE & SCIENCE, https://college.mayo.edu/academics/explore-health-care-careers/careers-a-z/surgical- first-assistant/ (last visited Dec. 9, 2024). 2 Surgical Technologist, MAYO CLINIC COLLEGE OF MEDICINE & SCIENCE, https://college.mayo.edu/academics/explore-health-care-careers/careers-a-z/surgical- technologist/ (last visited Dec. 9, 2024).

3 Appellate Case: 23-1344 Document: 59 Date Filed: 01/21/2025 Page: 4

applicants must complete a certain number of continuing education credits or retake the

examination. 3

Currently, ten states require an NBSTSA certification to practice as a Technologist

or Assistant. But NBSTSA—through AST (the professional association for

Technologists and co-defendant in this lawsuit)—lobbies for that number to increase.

FAC ¶ 15. Thus, while NBSTSA’s certifications remain voluntary in most states, “they

are nevertheless valuable” to Technologists and Assistants because “many employers

require” NBSTSA certification, “and such certifications are a pathway to higher pay and

upward mobility.” Ord. at 2; FAC ¶ 10. NBSTSA currently certifies 60,000

Technologists and Assistants across the nation and administers its certification exam to

roughly 11,000 candidates per year. FAC ¶ 11.

NBSTSA is not the only certifier of Assistants and Technologists. For Assistants,

the National Surgical Assistant Association (NSAA) and American Board of Surgical

Assistants (ABSA) offer competing certificates: the Certified Surgical Assistant (CSA)

and Surgical Assistant-Certified (SA-C). For Technologists, the National Center for

Competency Testing (NCCT) offer the Tech in Surgery (TS-C). The following table

summarizes these certifications:

3 Renewals & Recertification, NBSTSA, https://www.nbstsa.org/renewals- recertification (last visited Dec. 9, 2024); On Test Day, NBSTSA, https://www.nbstsa.org/test-day (last visited Dec. 31, 2024). Although ASA alleged “continuing education is mandatory for all CSTs and CSFAs,” FAC ¶ 13, that allegation is contradicted by NBSTSA’s website. On appeal, moreover, ASA does not dispute that CST and CSFA holders may recertify by retaking an exam. See, e.g., Aplt. Br. at 4, 16; Reply Br. at 7.

4 Appellate Case: 23-1344 Document: 59 Date Filed: 01/21/2025 Page: 5

Certifying Body Technologist certification Assistant Certification NBSTSA CST CSFA NSAA CSA ABSA SA-C NCCT TS-C

B. Certification Renewal / Recertification Services

NBSTSA requires its certificate holders to periodically renew their certifications.

Holders can renew two ways: (1) through completing continuing education credits or (2)

by retaking a certification exam. “Most renew” via continuing education credits. 4

According to ASA, NBSTSA has vested AST with sole authority to “approve, process,

and record [continuing education] credits”—which ASA calls “Recertification Services.”

FAC ¶¶ 14, 15.

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