This note begins by discussing the Hoover case in light of the actual holding by the Court. It then tracks the history of the Parker doctrine and examines the Court's progression in attempting to formulate a practical analysis for the state exemption. Finally, the note shows that Justice Powell's opinion in Hoover articulated a clear and workable analytical process based on, and consistent with, previous Court decisions.
Donald E. Harrop, Formulation of the Two Part Analysis for State Action Exemption - Hoover v. Ronwin, 7 Campbell L. Rev. 231 (1984).