Jefferson Parish Hospital District No. 2 v. Hyde

Jefferson Parish Hospital District No. 2 v. Hyde, 466 U.S. 2 (1984), was a United States Supreme Court case in which the Court held the analysis of the tying issue must focus on the hospital's sale of services to its patients, rather than its contractual arrangements with the providers of anesthesiological services.

Jefferson Parish Hospital District No. 2 v. Hyde
Argued November 2, 1983
Decided March 27, 1984
Full case nameJefferson Parish Hospital District No. 2, et al. v. Edwin G. Hyde
Citations466 U.S. 2 (more)
104 S. Ct. 1551; 80 L. Ed. 2d 2; 1984 U.S. LEXIS 49; 52 U.S.L.W. 4385; 1984-1 Trade Cas. (CCH) ¶ 65,908
Case history
PriorHyde v. Jefferson Parish Hosp. Dist. No. 2, 513 F. Supp. 532 (E.D. La. 1981); reversed, 686 F.2d 286 (5th Cir. 1982); cert. granted, 460 U.S. 1021 (1983).
Holding
The analysis of the tying issue must focus on the hospital's sale of services to its patients, rather than its contractual arrangements with the providers of anesthesiological services. In making that analysis, consideration must be given to whether petitioners are selling two separate products that may be tied together, and, if so, whether they have used their market power to force their patients to accept the tying arrangement.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William J. Brennan Jr. · Byron White
Thurgood Marshall · Harry Blackmun
Lewis F. Powell Jr. · William Rehnquist
John P. Stevens · Sandra Day O'Connor
Case opinions
MajorityStevens, joined by Brennan, White, Marshall, Blackmun
ConcurrenceBrennan, joined by Marshall
ConcurrenceO'Connor, joined by Burger, Powell, Rehnquist
Laws applied
Sherman Antitrust Act

In making that analysis, consideration must be given to whether petitioners are selling two separate products that may be tied together, and, if so, whether they have used their market power to force their patients to accept the tying arrangement. It set a permissive precedent in antitrust law, as some[who?] viewed tying as always anticompetitive.

Rationale

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Any inquiry into the validity of a tying arrangement must focus on the market or markets in which the two products are sold, for that is where the anticompetitive forcing has its impact. Thus, in this case, the analysis of the tying issue must focus on the hospital's sale of services to its patients, rather than its contractual arrangements with the providers of anesthesiological services. In making that analysis, consideration must be given to whether petitioners are selling two separate products that may be tied together, and, if so, whether they have used their market power to force their patients to accept the tying arrangement.[1]

There is no evidence that the price, quality, or supply or demand for either the "tying product" or the "tied product" has been adversely affected by the exclusive contract, and no showing that the market as a whole has been affected at all by the contract.[1] The case invokes the Clayton Antitrust Act of 1914, a notable piece of antitrust legislation.[2]

See also

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References

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  1. ^ a b "Jefferson Parish Hosp. Dist. v. Hyde, 466 U.S. 2 (1984)". Justia Law.
  2. ^ Hodgson, Matthew (2019). "No Such Thing as Partial Per se: Why Jefferson Parish v. Hyde Should be Abolished in Favor of a Rule of Reason Standard for Tying Arrangements". p. 315.
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