Med. Ctr. at Elizabeth Place, LLC v. Atrium Health Sys. — Mar. 2016 (Summary)

ANTITRUST

Med. Ctr. at Elizabeth Place, LLC v. Atrium Health Sys.
No. 14-4166 (6th Cir. Mar. 22, 2016)

The United States Court of Appeals for the Sixth Circuit reversed the holding of the district court, which had held that a hospital network was a single entity, and dismissed an antitrust case on summary judgment without adjudicating the question of whether the behavior of the network of hospitals constituted impermissible anticompetitive conduct.  The court of appeals found instead that a reasonable juror could determine that four hospitals that participated in a joint operating agreement were a “combination” for purposes of the antitrust laws, rather than a single entity that could not conspire with itself.

The court of appeals found that the complaint contained information that supported the plaintiff’s assertions that the defendant hospitals colluded to keep the plaintiff from competing in the local market.  The evidence included e-mails, letters, direct statements, and the fact that the defendants did not have any shared assets.  The court of appeals held that because the plaintiff presented the evidence above of conduct and business operations that raise the possibility of concerted action among the defendant hospitals, the question remains upon remand whether hospitals that had previously pursued their own interests separately and that continue to seem to compete, combined illegally in restraint of competition.  Thus, the court of appeals reversed the judgment of the district court and remanded the case.