United States Healthcare, Inc. v. Healthsource, Inc.

Healthsource offered its contracted primary-care physicians roughly a 14% pay increase in exchange for agreeing not to work with any other HMO, a policy cancelable on one month's notice, and U.S. Healthcare, seeking to enter the New Hampshire market, sued alleging the exclusivity arrangement was either a per se unlawful group refusal to deal or, under the rule of reason, unlawfully foreclosed competition in the HMO services market.