Summit Health, Ltd. v. Pinhas
United States Supreme Court
500 U.S. 322 (1991)
In 1981, Dr. Simon J. Pinhas (plaintiff) was employed as an eye surgeon on the staff of Midway Hospital Medical Center (Midway) (defendant), which was located in California and owned by Summit Health, Ltd. (Summit) (defendant). In 1986, the Medicare program announced that surgeons would no longer be reimbursed for the services of assistants. After the announcement, most of the hospitals in Southern California abandoned the practice of using an assistant surgeon. However, Midway continued to require an assistant surgeon for eye surgeries. As a result, Pinhas was personally obligated to pay for the services of an assistant. Pinhas advised Midway that he would quit if the requirement was not eliminated. Midway initially offered Pinhas a sham contract that would account for his out-of-pocket costs without increasing his obligations, but Pinhas refused. Midway then initiated a peer-review proceeding against Pinhas, which was carried out unfairly by a group of biased participants. Pinhas’s staff privileges at Midway were terminated, and Midway was preparing to send out a negative report of Pinhas that would make it very difficult for Pinhas to obtain employment as an eye surgeon. In response, Pinhas filed a complaint against Summit, Midway, and Midway’s medical staff, alleging that the defendants had engaged in a conspiracy to reduce competition in violation of § 1 of the Sherman Act. The district court dismissed Pinhas’s claim, but the court of appeals reinstated the antitrust claim on Pinhas’s appeal.
Rule of Law
Holding and Reasoning (Stevens, J.)
Dissent (Scalia, 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.