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Palmyra Park Hospital Inc v. Phoebe Putney Memorial Hospital

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Before TJOFLAT, PRYOR and MARTIN, Circuit Judges.

This is an antitrust case between two competing Georgia hospitals. Palmyra Park Hospital, Inc. (“Palmyra”) claims that Phoebe Putney Memorial Hospital (“Phoebe Putney”) leveraged a state-granted monopoly in certain medical services to tie favorable insurance reimbursement rates for those services to a refusal to include Palmyra, who competes with Phoebe Putney for the other medical services, in insurance companies’ provider networks. The district court dismissed Palmyra’s claims due to lack of antitrust standing. Specifically, the district court held that Palmyra was not an efficient enforcer of the antitrust laws. We disagree; Palmyra has antitrust standing to pursue its claims. We accordingly reverse the district court’s judgment and remand the case for further proceedings.

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