Patrick v. Burget

486 U.S. 94 (1988)

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Patrick v. Burget

United States Supreme Court
486 U.S. 94 (1988)

Facts

Timothy Patrick (plaintiff) was a general surgeon. Patrick worked as an employee at Columbia Memorial Hospital in Oregon. Columbia Memorial Hospital had several independent physicians, but the vast majority of physicians working there belonged to a private group practice, the Astoria Clinic. The partners of this practice, including William M. Burget (defendants), eventually invited Patrick to join them as a partner, but Patrick preferred to remain independent. After this, the partners refused to have anything to do with Patrick’s practice, and they would not send him referrals. The partners also filed several complaints about Patrick with the State Board of Medical Examiners. The State Board of Medical Examiners at one point issued a written reprimand of Patrick, but when Patrick sought judicial review of the reprimand, the board changed its mind and retracted the reprimand. In addition, Columbia Memorial Hospital voted to terminate Patrick’s hospital privileges, but Patrick resigned from the hospital before this could go into effect. Although the state of Oregon had written laws mandating the procedures that hospitals were to follow in deciding whether to terminate a physician’s hospital privileges, no state government officials had any actual authority or say over the substance of whether to terminate such privileges. The Oregon Supreme Court, furthermore, had traditionally expressed skepticism about whether that state’s courts could give judicial review of any decision terminating such privileges. Patrick brought suit in federal district court against the partners of the Astoria Clinic, alleging violations of the Sherman Act and that the partners had utilized the hospital’s peer-review process to reduce his ability to compete with them. The district court awarded judgment to Patrick, but the court of appeals reversed on the ground that the antitrust state-action doctrine immunized the conduct of the defendants. Patrick sought review in the United States Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Marshall, J.)

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