Jackson, Tennessee Hosp. Co., LLC v. West Tennessee Healthcare
Inc.,
No.1-03-1166-T (W.D. Tenn. (Feb. 27, 2004)
The United States District Court for the Western District of Tennessee granted a healthcare organization and insurance company's motion to dismiss a complaint brought against them by a hospital, alleging violations of state and federal antitrust laws.
In holding for the defendants, the court relied on the state action doctrine, and held that the defendants were immune from antitrust liability because anticompetitive effects were the logical and foreseeable result of the broad authority to own, operate and manage hospitals and other health care facilities that two 1995 and 1996 state acts conferred on the defendants. Accordingly, the defendants' motion to dismiss was granted because they were immune from antitrust liability under the state action immunity doctrine.