Saint Alphonsus Med. Ctr. – Nampa, Inc. v. St. Luke’s Health Sys., Ltd. — Mar. 2016 (Summary)

ANTITRUST – ATTORNEY’S FEES

Saint Alphonsus Med. Ctr. – Nampa, Inc. v. St. Luke’s Health Sys., Ltd.
Case No. 1:12-CV-00560-BLW (D. Idaho Mar. 28, 2016)

The District Court for the District of Idaho unwound a merger between a health system and medical group brought by another hospital and the state of Idaho due to the potential anticompetitive effects of the merger.  In a subsequent proceeding to determine whether the plaintiff hospital was entitled to attorney’s fees, the district court rejected the defendant hospital’s argument that 80% of the attorney’s fees sought by the plaintiff hospital were related to matters never ruled upon by the court.  The district court stated it was appropriate to “defer to the winning lawyer’s professional judgment,” and that the “vast majority” of the work performed on behalf of the plaintiff hospital was related to the anticompetitive effects the merger would have on the adult primary care market.  However, the district court reduced the attorney’s fees awarded to the counsel for the plaintiff hospital by 10%, holding that this amount of the work represented time the attorney did not spend working on relevant issues.

The district court rejected the health system’s and medical group’s argument that the attorney for the plaintiff hospital exaggerated the number of hours the attorney spent on the case.  Although the government and private plaintiff were found to spend approximately 229% of the total time spent by the hospital preparing for the case, the district court held that opposing counsel’s billing records were not dispositive on the issue.  Based upon billing information the hospital had submitted in a prior case and the lack of evidence presented by the hospital to support its claim, the district court rejected the hospital’s argument that the reported hours spent by the private plaintiff and government were unreasonable.

The district court also found an award of attorney’s fees for travel expenses to be appropriate.  Although the Idaho Court of Appeals had recently held attorney’s fees would only be awarded as a sanction, the district court found the complicated healthcare antitrust case warranted specialized counsel not available within the jurisdiction.  Additionally, because the district court placed the parties on a fast track discovery schedule, the attorneys often needed to travel extensively to meet tight deadlines.  The district court found the travel costs sought by the private plaintiff’s counsel to be reasonable.  The private plaintiff was also entitled to interest on the attorney’s fees award until paid by the hospital.