Zoellner v. St. Luke’s Reg’l Med. Ctr., Ltd. (Summary)

ANTITRUST

Zoellner v. St. Luke’s Reg’l Med. Ctr., Ltd., No. 1:11-cv-00382-EJL (D. Idaho Mar. 31, 2013)

The U.S. District Court for the District of Idaho granted in part and denied in part a hospital’s motion to dismiss an anesthesiologist’s suit alleging state and federal antitrust violations and state law tortious interference claims.  The anesthesiologist was allegedly forced to resign his employment with an anesthesiology group, which had an exclusive contract to provide anesthesia services at the hospital.  The anesthesiologist claimed that the hospital pressured the group to force his resignation because of his complaints that the neurosurgeons at the hospital were “scheduling surgeries at times that are not in the patients’ best interests.”

The hospital filed a motion to dismiss the anesthesiologist’s suit.  The court dismissed the anesthesiologist’s antitrust claims, concluding that he failed to allege “antitrust injury” through a showing of reduced competition in the market for anesthesiology services because of his alleged forced resignation.  The court also rejected the anesthesiologist’s state law intentional interference with contract claim because such claims are not recognized in Idaho when an employment contract can be terminated without cause, as was the case here.  However, the court allowed the anesthesiologist’s intentional interference with prospective economic advantage claim to go forward, finding that whether the hospital’s alleged interference with the anesthesiologist’s employment was “wrongful” was a question of fact that could not be resolved in a motion to dismiss.