Parikh v. Franklin Medical Center

940 F. Supp. 395 (1996)

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Parikh v. Franklin Medical Center

United States District Court for the District of Massachusetts
940 F. Supp. 395 (1996)

  • Written by Heather Whittemore, JD

Facts

Franklin Medical Center (Franklin) (defendant) was an acute-care community hospital in Greenfield, Massachusetts. Though Franklin was the only acute-care provider in its county, four other hospitals were located within a 30-mile radius. In 1990 Dr. Nitin P. Parikh (plaintiff), an anesthesiologist, was hired by Franklin to direct its anesthesia department. Parikh and Franklin entered into an exclusive contract under which Parikh had the exclusive right to practice anesthesiology at Franklin and to appoint all future anesthesiologists and nurse anesthetists. The contract provided for an automatically renewable five-year term and allowed Franklin to fire Parikh for material breaches of the contract. Parikh agreed to the contract because it ensured that he had stable work for five years and had control over his department. In 1995, after Franklin disagreed with Parikh’s decision to not employ another anesthesiologist, Dr. Sudershan Singla, Franklin did not renew its contract with Parikh but did not identify a material breach of the contract committed by Parikh. Parikh sued Franklin in federal district court to enforce his exclusive right to practice anesthesiology at Franklin. Franklin and Singla filed a counterclaim against Parikh seeking a declaration that the exclusive-dealing arrangement violated § 1 of the Sherman Act. Franklin and Singla argued that the exclusive-dealing contract, under which Parikh could oppose staff appointments, resulted in a reduced supply of anesthesiologists practicing at Franklin. The parties disputed the relevant geographic market. Franklin and Singla moved for summary judgment.

Rule of Law

Issue

Holding and Reasoning (Ponsor, J.)

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