Saint Alphonsus Medical Center-Nampa Inc.; Federal Trade Commission & State of Idaho v. St. Luke's Health System
9th Circuit
778 F.3d 775 (2015)
St. Luke's Health System (St. Luke's) (defendant) acquired the assets of Saltzer Medical Group, the Nampa, Idaho market's largest primary-care physician group, and entered agreements with its physicians. Saint Alphonsus Health System (the only Nampa hospital), the FTC, and Idaho (plaintiffs) sued to block the merger under Clayton Act § 7 for its anticompetitive effects on primary-care physician services; St. Luke's argued the merger's anticipated efficiencies excused any anticompetitive price effects, but the trial court found those efficiencies were not actually dependent on the merger and ordered divestiture, and St. Luke's appealed.
Whether healthcare providers seeking to merge may escape a charge of anticompetitive practice solely by claiming the merger would improve the efficiency of providing care.