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Hassan v. Independent Practice Associates, P.C.

United States District Court for the Eastern District of Michigan
698 F. Supp. 679 (1988)


Facts

Health Plus (defendant) was a health-maintenance organization (HMO) that served 20 percent of the health-coverage needs in its area. Health Plus competed heavily with several other HMOs and insurance companies and needed to keep its medical costs down in order to offer attractive subscriber prices and remain competitive. Independent Practice Associates, P.C. (IPA) (defendant) was a group of doctors that provided all the medical services for the Health Plus subscribers. Although 75 percent of the area doctors belonged to IPA, IPA allowed its members to belong to other networks and to generally provide medical services outside the Health Plus network. Dr. Shawky Hassan and Dr. Fikria Hassan (plaintiffs) were allergy specialists who belonged to IPA. The Hassans ran laboratory tests to check their patients’ allergies much more often than did other allergy specialists. IPA reviewed the patient files and determined that the high testing rate was not justified. However, Health Plus was obligated to pay the Hassans for each of these tests, which drove up its overall costs. To control the group’s costs, IPA terminated the Hassans’ membership in IPA, which excluded them from serving Health Plus subscribers. The Hassans sued, alleging that IPA’s act of excluding them from its network violated antitrust laws.

Rule of Law

Issue

Holding and Reasoning (Newblatt, J.)

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