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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.)
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