Medical Center at Elizabeth Place v. MedAmerica Health Systems et al.

Date Filed: January 30, 2012
Status: Pending
District Court: S.D. Ohio – Case No. 3:12-CV-00026
Appellate Court: 6th Circuit Case Nos. 14-4166, 17-3863
Nature of Suit: Antitrust
Defendant Type: Provider
Plaintiff Type: Private
Court Document:

In 2013, a Dayton physicians’ speciality hospital sued a group of larger hospitals, alleging a boycott conspiracy in violation of Section 1 of the Sherman Act. The specialty hospital accused the larger group, operating as an alliance, of conspiring to exclude it from managed care contracts, depriving it of a significant amount of business. The court ruled in late 2014 that the alliance was a single entity for Sherman Act purposes, and thus incapable of engaging in a conspiracy. This result raises the question of how such a case might be decided if it were instead brought as a Sherman Act Section 2 monopolization case. The Sixth Circuit reversed and remanded the district court’s judgment in March 2016, disagreeing that the alliance was a single entity and therefore the outstanding issue of material fact precluded summary judgment on restraint of trade claim. On August 9, 2017, the district court once again dismissed Plaintiff’s Sherman Act claim with prejudice, finding Plaintiff’s Sherman Act claim not subject to per se condemnation. Plaintiffs appealed the judgment and the Sixth Circuit set oral argument for April 25, 2018.

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