Sidibe v. Sutter Health (Summary)

ANTITRUST

Sidibe v. Sutter Health, No. C 12-04854 LB (N.D. Cal. Nov. 7, 2013)

The United States District Court for the Northern District of California granted a health system’s motion to dismiss in this putative class action suit brought by two individuals enrolled in commercial health plans (the “insureds”) alleging antitrust violations.  The insureds claimed that the health system violated state and federal antitrust laws by requiring payers: (1) to contract with all of the health system’s providers to have access to any of its providers, and (2) to “steer” patients to the health system’s providers.

In dismissing the complaint, the court found that the insureds failed to allege the relevant inpatient hospital services geographic markets to support its Sherman Act claims. The court also concluded that the insureds did not adequately allege a tying claim because they failed to plead facts showing any negative impact on competition.  Lastly, because the insureds were found not to have alleged the relevant inpatient hospital services geographic markets, the court dismissed the monopolization and attempted monopolization claims as well.  Even though the court granted the health system’s motion to dismiss, it granted the insureds leave to amend their complaint.