Med. Consultants v. Iroquois Mem’l Hosp.

EXCLUSIVE CONTRACTS

Med. Consultants v. Iroquois Mem’l Hosp., No. 07-CV-2083 (C.D.Ill.
June 16, 2008)

The United States District Court for the Central District of Illinois granted
a hospital’s motion to dismiss an antitrust lawsuit filed by a radiologist, challenging
the hospital’s right to enter into an exclusive contract with a radiology group,
holding that the radiologist’s purported injuries did not rise to the level of
anticompetitive behavior. The radiologist argued that the hospital’s conduct
resulted in a decline in his services, but failed to prove that the hospital’s
conduct resulted in a decline in the availability of radiological services in
the community in general. The radiologist also failed to prove that the quality
of radiological services had declined, arguing simply that the hospital had an
impact on the convenience of doctors to have a particular radiologist. Ultimately,
the court held that the radiologist’s purported injuries did not constitute a
loss that stems from a competition-reducing aspect or effect of the hospital’s
behavior.