Federal Trade Commission v. Phoebe Putney Health System, Inc.
United States Supreme Court
133 S. Ct. 1003 (2013)
Phoebe Putney Memorial Hospital (Memorial) and Palmyra Medical Center (Palmyra) were the only hospitals in Doughtery County, Georgia. Together, the two hospitals accounted for 86 percent of the market for acute hospital services in the area. In 2010, the owner of Memorial, Phoebe Putney Health System, Inc. (PPHS) (defendant), came up with a plan to purchase Palmyra. Under an amendment to the state constitution that was intended to increase access to affordable health care, substate government entities could establish local hospital authorities with the power to acquire, purchase, or lease hospitals and other health facilities. PPHS went to the Hospital Authority of Albany-Dougherty County (the Authority) (defendant) and proposed a plan in which the Authority would purchase Palmyra with PPHS funds and then lease Palmyra back to PPHS for $1 per year. The Authority agreed to the proposal, which effectively granted PPHS a monopoly in the market for hospital services in the area. The Federal Trade Commission (FTC) (plaintiff) brought a complaint against PPHS and the Authority, alleging antitrust violations. The Authority claimed immunity from antitrust liability under the state-action doctrine. The district court found for the Authority and PPHS. The FTC appealed the decision.
Rule of Law
Holding and Reasoning (Sotomayor, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 177,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.