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Antitrust Keyed to Gavil, 5th Ed.
Jefferson Parish Hospital District No. 2 v. Hyde
Citation:
466 U.S. 2 (1984)Facts
In 1971, East Jefferson Hospital entered into an exclusive “Anesthesiology Agreement” with Roux & Associates, a professional medical corporation. The contract provided that only anesthesiologists from Roux would be admitted to the hospital’s medical staff to provide anesthesiology services. The hospital agreed to provide space, equipment, and support services for the anesthesiology department. In 1976, a second contract was executed with similar provisions, though the explicit exclusivity clause was removed; nevertheless, the hospital continued to operate a closed anesthesiology department. In 1977, Dr. Edwin Hyde, a board-certified anesthesiologist, applied for admission to the hospital’s medical staff but was denied because of the exclusive arrangement with Roux. The hospital was one of at least 20 hospitals in the New Orleans metropolitan area, and about 70% of Jefferson Parish residents used hospitals other than East Jefferson. At the time of trial, Roux employed four anesthesiologists, and the hospital employed 13-14 certified registered nurse anesthetists.
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