On April 29, 2026, US District Judge John F. Murphy dismissed the class action lawsuit against the Law School Admission Council (LSAC) and 197 ABA-approved member law schools over alleged price-fixing of application fees. However, the dismissal came without prejudice, meaning plaintiff Linvel Risner received until May 12, 2026 to file an amended complaint—keeping the core case alive.
While the judge found the initial allegations “implausible” and the complaint “unclear and self-contradictory,” he acknowledged the lawsuit “is not without its merits,” leaving room for the plaintiff to strengthen the legal arguments and resubmit. This dismissal represents a critical juncture in antitrust litigation against the law school admissions system. Rather than ending the case permanently, the ruling essentially gave Risner a roadmap: clarify the market definitions, make the monopoly claims more plausible, and resolve internal contradictions. For prospective law students paying $85 to $245 per application across multiple schools, the lawsuit’s survival—even in limited form—matters because it keeps pressure on LSAC and member schools to justify their fee structures.
Table of Contents
- What the Judge Found Wrong With the Original Complaint
- The Underlying Allegations and Market Manipulation Claim
- The Defendants and Their Coordinating Role
- The Amended Complaint Deadline and What Comes Next
- Why the Judge’s “Not Without Merits” Language Matters
- Application Fee Impacts on Law School Access
- Comparable Antitrust Challenges in Education
- Frequently Asked Questions
What the Judge Found Wrong With the Original Complaint
The judge’s April 2026 ruling dismissed all three counts of the complaint, but for a specific reason: the plaintiff failed to adequately define the proposed antitrust markets. In antitrust litigation, defining the relevant market is foundational. Without a clear market definition—whether you’re talking about “law school admissions services” broadly, “LSAC’s specific services,” or “regional law school admissions”—courts cannot evaluate whether defendants actually monopolized or fixed prices within that market.
Judge Murphy’s language was sharp but not dismissive. He called the allegations implausible and self-contradictory, suggesting internal inconsistencies that undermined the legal theory. However, by ruling without prejudice and explicitly noting the lawsuit “is not without its merits,” the judge signaled that a more carefully drafted complaint addressing these flaws could survive. This is meaningful: the judge did not say the claims are frivolous or that no law school admission fee conspiracy could ever be proven.
The Underlying Allegations and Market Manipulation Claim
The lawsuit, originally filed in August 2025, accuses LSAC and 197 member law schools of conspiracy to fix application fees and monopolize the law school admissions process under the Sherman Antitrust Act. The allegation is that by coordinating through LSAC or by refusing to use alternative admissions platforms, these institutions artificially kept application fees high and locked prospective students into using LSAC’s services as the gatekeeping mechanism for law school entry. A critical limitation in the original complaint was its failure to articulate how applicants suffered actual antitrust injury from these fees.
Antitrust claims require showing that competition was suppressed and consumers were harmed. If the court cannot understand which market was allegedly monopolized—is it the market for admissions testing, the market for admissions processing, or the market for law school enrollment itself?—it cannot assess whether the conspiracy actually harmed students. This ambiguity was central to the judge’s dismissal reasoning.
The Defendants and Their Coordinating Role
The defendants include LSAC, the nonprofit organization that administers the Law School Admission Test (LSAT) and manages the centralized application service, plus 197 ABA-approved law schools that use LSAC’s infrastructure. LSAC’s role is particularly significant because it controls the primary gatekeeper function for law school admissions. If LSAC and member schools coordinate on application fee levels through LSAC’s policies or pricing recommendations, that coordination could theoretically suppress competition on admissions processing costs—a key ingredient in price-fixing allegations.
However, proving conspiracy requires demonstrating that schools consciously coordinated rather than independently setting fees. The original complaint apparently failed to present facts showing an agreement or meeting of the minds. The amended complaint will need to include specific evidence: internal communications, fee-setting meetings, industry emails, or other documents suggesting coordinated action rather than parallel behavior.
The Amended Complaint Deadline and What Comes Next
Linvel Risner had until May 12, 2026 to file an amended complaint addressing the judge’s concerns. This deadline structure—giving the plaintiff a defined opportunity to fix pleading defects—is standard in federal civil litigation and reflects Rule 15 of the Federal Rules of Civil Procedure. In practice, this means the plaintiff’s legal team must now do significantly more work: define the relevant market clearly, remove contradictions, and connect the alleged fee-fixing to specific harm suffered by applicants.
If Risner submits an amended complaint that addresses the market definition issue and removes implausible allegations, the case moves past the dismissal hurdle and into the discovery phase. If the amended complaint still fails to state a plausible claim, the defendants can file another motion to dismiss. This iterative process—dismiss without prejudice, allow a refile, dismiss again if still deficient—is how federal courts manage poorly pleaded complaints while giving plaintiffs a fair opportunity to develop their case.
Why the Judge’s “Not Without Merits” Language Matters
The judge’s observation that the lawsuit “is not without its merits” is crucial because it distinguishes this case from frivolous litigation. A truly frivolous case would be dismissed with prejudice (meaning it cannot be refiled), and the judge would use dismissive language: clearly baseless, obviously implausible, no reasonable person could believe this. Instead, Judge Murphy’s framing suggests the legal theory—that law schools and LSAC conspired to fix or inflate application fees—has some theoretical plausibility.
The problem was execution: the plaintiff had not yet proven it persuasively in the pleadings. A limitation of the judge’s ruling is that it does not signal how high the bar actually is for the amended complaint. The plaintiff must clear the pleading standard known as “plausibility,” which requires alleging facts that make the claimed conspiracy plausible—not just possible. This is a nuanced standard, and plaintiffs often struggle to meet it in antitrust cases because defendants rarely leave a paper trail admitting a conspiracy, and parallel behavior by competitors can look like coordination even without an actual agreement.
Application Fee Impacts on Law School Access
Law school application fees range from $85 to $245 per application depending on the school, and most applicants submit 5 to 15 applications to optimize their chances of admission and scholarship offers. For a student applying to 10 schools at an average of $150 per application, the total admissions cost reaches $1,500 before considering LSAT preparation courses (which can cost $300 to $2,000) and application preparation services.
This aggregate expense creates a real barrier for low-income prospective law students. If LSAC and member schools genuinely conspired to keep these fees artificially high, the injury extends beyond individual applicants to the legal profession itself: fewer low-income students can afford to apply, reducing diversity in law school cohorts and ultimately in the legal market. This connection between admission costs and professional diversity is why federal courts take antitrust claims in education seriously, even when pleading defects require dismissal.
Comparable Antitrust Challenges in Education
The LSAC price-fixing lawsuit is not the first time applicants have challenged standardized admissions gatekeepers under antitrust law. The SAT and ACT have faced similar allegations from high school applicants, though those cases have had mixed results. The challenge in all these cases is proving that the testing organization and affiliated educational institutions agreed to suppress competition rather than simply charging independently for their services.
Medical school admissions (AMCAS) and business school admissions (GMAC) have also faced scrutiny, though enforcement has been limited. The distinction between permissible independent fee-setting and illegal price-fixing turns on evidence of agreement. A memo from LSAC recommending fee levels to member schools looks like coordination; schools independently deciding their own application fees without communication looks like competition. The amended complaint Risner filed (or will file) must walk this evidentiary line and present facts suggesting actual coordination rather than parallel business decisions.
Frequently Asked Questions
Was the LSAC lawsuit completely thrown out?
No. The April 2026 dismissal was without prejudice, allowing the plaintiff to refile an amended complaint by May 12, 2026. If the new complaint addresses the judge’s concerns—particularly clarifying what antitrust market was allegedly monopolized—the case can proceed past the pleading stage.
What did the judge say was wrong with the original complaint?
The judge found the allegations implausible, the complaint unclear and self-contradictory, and critically, the plaintiff failed to adequately define the relevant antitrust market. Without knowing which market allegedly was monopolized, the court could not evaluate the price-fixing claim.
Can LSAC be sued again if the amended complaint is also dismissed?
Yes. If the plaintiff files an amended complaint and it is also dismissed with prejudice (rather than without prejudice), that would bar future suits on the same claims. However, a dismissal without prejudice allows refiling with further amendments.
Who exactly was sued in this case?
The lawsuit names LSAC and 197 ABA-approved member law schools as defendants, alleging they conspired to fix application fees and monopolize the law school admissions process under the Sherman Antitrust Act.
How much does it cost to apply to law school?
Individual application fees range from $85 to $245 per school. A student applying to 10 schools could spend $1,500 just on application fees, before LSAT prep and other admissions-related expenses. High aggregate costs can prevent low-income applicants from applying broadly.
What happens if Risner’s amended complaint is found to have merit?
The case would enter the discovery phase, where both sides exchange documents, emails, and other evidence. If LSAC and member schools coordinated fee-setting, internal communications from those organizations could prove the conspiracy. The case would then potentially proceed to summary judgment or trial.
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