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

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