Jefferson Parish Hospital District No. 2 v. Hyde

East Jefferson Hospital (defendant) had an exclusive contract making Roux & Associates its only provider of anesthesiology services, with anesthesiology billed separately from other hospital fees. When Hyde (plaintiff) was denied privileges to practice anesthesiology at the hospital because of this exclusivity deal, he sued, arguing the arrangement was an illegal tying arrangement under antitrust law, supported by evidence that patients often wanted specific anesthesiologists the contract prevented them from choosing. The hospital countered that 70 percent of patients in the area used other hospitals, meaning it lacked market power to cause real competitive harm; the district court agreed and also found the arrangement's benefits outweighed its harms, but the court of appeals reversed, holding the hospital did have market power making the contract per se illegal. The hospital appealed.