Little Rock Cardiology Group v. Baptist Health

ANTITRUST AND SPECIALTY HOSPITALS

Little Rock Cardiology Group v. Baptist Health, No. 4:06CV01594 JLH (E.D. Ark. Aug. 29, 2008)

The United States District Court for the Eastern District of Arkansas dismissed all claims brought by a cardiology clinic in its antitrust suit against a health system and insurance company and held that the clinic’s claims related to the health insurance industry were barred by the statute of limitations and that claims regarding services to cardiology patients failed to plead a relevant product market and alleged a geographic market that was too narrow.

The insurance company terminated its provider network participation agreements with the clinic and its physician after the clinic, along with other investors, opened a cardiac hospital. Several years later, the hospital adopted an "economic credentialing policy" which prohibited any doctor having privileges at the health system from holding an interest in a competing hospital. The clinic alleged that this termination and the subsequent economic credentialing policy were the result of a conspiracy between the health system and the insurance company in an attempt to monopolize the market for cardiology services for privately insured patients and the market for private health insurance in central Arkansas.

In dismissing all of the claims brought by the clinic, the district court held that the statute of limitations barred the clinic’s claims concerning the health insurance market and that subsequent refusals by the insurer to readmit the clinic and its physicians were simply "reaffirmation[s]" of the original exclusion. Further, it was concluded that the clinic did not allege a relevant product market because, contrary to the clinic’s claims, the hospital did not provide cardiologist services and, therefore, could not monopolize that market. On a similar note, the alleged geographic market was deficient in including only the cities of Little Rock and North Little Rock because such an allegation only addressed where patients actually go for services and not where they could go for services.