MacManus v. Chattanooga-Hamilton County Hosp. Auth.

JURISDICTION IN HCQIA CASES

MacManus v. Chattanooga-Hamilton County Hosp. Auth., No. 1:08-cv-96 (E.D. Tenn. May 19, 2008)

The United States District Court for the Eastern District of Tennessee found that a hospital did not create federal jurisdiction by evoking the Health Care Quality Improvement Act of 1986 ("HCQIA") as its defense to a lawsuit brought by a physician. The physician alleged that the hospital was liable for breach of contract, tortious interference with a contractual relationship, and interference with prospective business advantages after it suspended his medical staff privileges. The hospital removed the case to federal court, asserting federal question jurisdiction on the basis that the affirmative defenses it intended to assert would invoke the HCQIA. However, the court remanded the case back to state court, holding that a federal court does not have jurisdiction over a case when federal law is evoked by a defense. The court also found that the physician could establish each of the elements of his claims without any reference to federal law.