Omni Healthcare, Inc. v. Health First, Inc. (Summary)

ANTITRUST

Omni Healthcare, Inc. v. Health First, Inc., No. 6:13-cv-1509-Orl-37DAB (M.D. Fla. Jan. 22, 2015)

The U.S. District Court for the Middle District of Florida denied a health system’s motion to dismiss in an antitrust suit brought by a number of physicians and practice groups. The plaintiff physicians alleged that the defendant system, which was described in the complaint as a “fully integrated” healthcare corporation consisting of a hospital, an insurance company and a physician group, engaged in an anti-competitive scheme to monopolize health care markets in Southern Brevard County, Florida.

The court held that the physicians had sufficiently alleged antitrust injury because they claimed to have suffered a competitive injury due to the actions of the defendants. The court rejected the defendants’ arguments that plaintiffs had to be “consumers or competitors” to allege antitrust injury. The court also found that the physician groups adequately defined the relevant product and geographic markets, ruling that they sufficiently alleged the product dimensions and geographical boundaries of the service market. Finally, the court found that the plaintiffs stated a plausible claim for conspiracy when they alleged that physicians who refused to join the system or enter into an exclusive referral arrangement with it were blacklisted.