The United States Court of Appeals for the First Circuit ruled that an anesthesiologist's identification of a relevant geographic market was adequate to survive a motion to dismiss.

The anesthesiologist had been employed by a provider with an exclusive contract with a hospital. She was fired by the provider and, thus, could no longer provide services at the hospital. She sued, claiming that the exclusive contract violated the antitrust laws by excluding her from all outlets for her services that were reasonably available. The defendants filed a motion to dismiss, claiming that the geographic market had not been properly identified. The court ruled that the issue could not be decided on a motion to dismiss, and denied the defendants' motion to dismiss.