Summit Health, Ltd. v. Pinhas
United States Supreme Court
500 U.S. 322 (1991)
Dr. Simon Pinhas (plaintiff), an eye surgeon, refused a sham contract offered by Midway Hospital (Midway) (defendant), owned by Summit Health (Summit) (defendant), after Medicare stopped reimbursing assistant-surgeon costs and Midway continued requiring assistant surgeons anyway; when Pinhas threatened to quit rather than personally absorb the cost, Midway initiated an allegedly unfair peer-review proceeding that terminated his staff privileges and prepared a damaging report about him. Pinhas sued Summit, Midway, and Midway's medical staff for antitrust conspiracy under § 1 of the Sherman Act, the district court dismissed his claim, and the court of appeals reinstated it.
Whether, to establish federal jurisdiction for an antitrust complaint, a plaintiff must show that a challenged restraint has actually affected interstate commerce.