US: Judge Sixth Circuit decision affirms Summary Judgment against hospital antitrust challenge
Last month, in The Medical Center at Elizabeth Place, LLC v. Atrium Health System, et al., a three-judge panel of the US Court of Appeals for the Sixth Circuit affirmed 2-1 the district court’s grant of summary judgment dismissing plaintiff The Medical Center at Elizabeth Place’s (MCEP) federal antitrust conspiracy claims against four defendant hospital systems and the company under which they operate.
In affirming the district court, the Sixth Circuit held that defendants’ conduct was ancillary to a joint venture, meaning it was plausibly related to the efficiency-enhancing purpose of the joint venture and thus properly analyzed under the rule of reason, which evaluates and balances the conduct’s anticompetitive harms and procompetitive benefits. The plaintiff argued that the joint venture’s conduct should have been analyzed under the stricter rule of per se illegality, which would have only required plaintiff to establish that defendants entered into the challenged conspiracy, without having to show the challenged conduct had an actual anticompetitive effect.
The Sixth Circuit’s decision caps a lengthy seven-year battle between the parties that has included two decisions on dispositive motions from the district court and one prior appellate opinion from the Sixth Circuit.
Full Content: Mondaq
Want more news? Subscribe to CPI’s free daily newsletter for more headlines and updates on antitrust developments around the world.
Featured News
Redfin Settles $9.2M Commission Inflation Lawsuits
May 7, 2024 by
CPI
DOJ Supports Colorado’s Efforts to Block Kroger-Albertsons Merger
May 7, 2024 by
CPI
Japan Considers Regulation of AI Developers
May 7, 2024 by
CPI
European Commission Extends Decision Deadline for Ita-Lufthansa Merger
May 7, 2024 by
CPI
UK, US and Australia Sanction Senior Leader of LockBit Cybercrime Gang
May 7, 2024 by
CPI
Antitrust Mix by CPI
Antitrust Chronicle® – Economics of Criminal Antitrust
Apr 19, 2024 by
CPI
Navigating Economic Expert Work in Criminal Antitrust Litigation
Apr 19, 2024 by
CPI
The Increased Importance of Economics in Cartel Cases
Apr 19, 2024 by
CPI
A Law and Economics Analysis of the Antitrust Treatment of Physician Collective Price Agreements
Apr 19, 2024 by
CPI
Information Exchange In Criminal Antitrust Cases: How Economic Testimony Can Tip The Scales
Apr 19, 2024 by
CPI