What is the current state of the federal court's interpretation of the Sherman Act?

Since McLain, the federal courts have embarked upon a new and vastly expanded interpretation of the interstate commerce requirement under the Sherman Act. As a result the courts have been deluged with complaints alleging that a hospital's denial of a doctor's staff privileges constitutes a Sherman Act violation. Marrese v. Interqual, Inc., 748 F.2d 373, 381 (7th Cir.1984), cert. denied, ___ U.S. ___, 105 S.Ct. 3501, 87 L.Ed.2d 632 (1985) (see cases cited therein). A common, albeit differently interpreted threshold issue which has been presented in each of the cited cases is whether a doctor's complaint alleges facts sufficient to satisfy the jurisdictional requirement of interstate commerce under the Sherman Act.