FTC v. Phoebe Putney Health System (2012)
- Docket
- 11-1160
- Decided
- 2012-01-01
Summary
Question: Does the state-action doctrine immunize a statutorily created hospital authority from antitrust liability for anti-competitive acts? Conclusion: No. Justice Sonia Sotomayor, delivering a unanimous opinion, reversed the lower court's decision and remanded for further proceedings. The Court held that state-action immunity does not apply because the Georgia legislature did not clearly articulate any intent to allow anticompetitive activity through the Hospital Authorities Law. A state legislature is not required to expressly state this intent. State-action immunity applies if the anticompetitive effect was a foreseeable result of the State's legislation. However, the Court found no evidence that the State anticipated, or even contemplated, that hospital authorities would displace competition. While the Hospital Authorities Law grants hospital authorities general powers to participate in the marketplace, it does not allow them to use those powers anticompetitively.