Jefferson Parish Hospital District No. 2 v. Hyde
United States Supreme Court
466 U.S. 2 (1984)
In 1971, East Jefferson Hospital (Jefferson Hospital) (defendant) entered into an agreement with Roux & Associates (Roux) that established Roux as the exclusive provider of Jefferson Hospital’s anesthesiological services. Under the agreement, any fees for anesthesiology were billed separately to patients, with payments divided between Jefferson Hospital and Roux. Under the agreement, only anesthesiologists from Roux were able to practice anesthesiology at Jefferson Hospital. In 1977, Edwin G. Hyde (plaintiff) applied to become an anesthesiologist at Jefferson Hospital. Hyde was ultimately denied due to Jefferson Hospital’s exclusivity agreement with Roux. In response, Roux sued Jefferson Hospital, seeking an injunction and a declaratory judgment that the agreement with Roux violated antitrust law. Hyde argued the agreement was an unlawful tying arrangement. Hyde presented evidence showing that patients often request specific anesthesiologists, which the contract prevented. Jefferson Hospital presented evidence that 70 percent of patients in the area attended hospitals other than Jefferson Hospital, arguing that it lacked sufficient market power to cause competitive harm. The district court agreed, ruling that Jefferson Hospital did not possess market power in the relevant geographic market. The court also ruled the pro-competitive benefits of the contract outweighed the anticompetitive harm. The court of appeals reversed, holding Jefferson Parish did possess market power, which rendered the contract per se illegal. Jefferson Hospital appealed.
Rule of Law
Holding and Reasoning (Stevens, J.)
Concurrence (Brennan, J.)
Concurrence (O’Connor, 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 175,000 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.