Jefferson Parish Hospital District No. 2 v. Hyde

Jefferson Parish Hospital District No. 2 v. Hyde, 466 U.S. 2 (1984), was a United States Supreme Court case in which the Court held the analysis of the tying issue must focus on the hospital's sale of services to its patients, rather than its contractual arrangements with the providers of anesthesiological services. In making that analysis, consideration must be given to whether petitioners are selling two separate products that may be tied together, and, if so, whether they have used their market power to force their patients to accept the tying arrangement. It set a permissive precedent in antitrust law, as some viewed tying as always anticompetitive.

Jefferson Parish Hospital District No. 2 v. Hyde
Supreme Court of the United States
Argued November 2, 1983 Decided March 27, 1984
Full case name	Jefferson Parish Hospital District No. 2, et al. v. Edwin G. Hyde
Citations	466 U.S. 2 (more) 104 S. Ct. 1551; 80 L. Ed. 2d 2; 1984 U.S. LEXIS 49; 52 U.S.L.W. 4385; 1984-1 Trade Cas. (CCH) ¶ 65,908
Case history
Prior	Hyde v. Jefferson Parish Hosp. Dist. No. 2, 513 F. Supp. 532 (E.D. La. 1981); reversed, 686 F.2d 286 (5th Cir. 1982); cert. granted, 460 U.S. 1021 (1983).
Holding
The analysis of the tying issue must focus on the hospital's sale of services to its patients, rather than its contractual arrangements with the providers of anesthesiological services. In making that analysis, consideration must be given to whether petitioners are selling two separate products that may be tied together, and, if so, whether they have used their market power to force their patients to accept the tying arrangement.
Court membership
Chief Justice Warren E. Burger Associate Justices William J. Brennan Jr. · Byron White Thurgood Marshall · Harry Blackmun Lewis F. Powell Jr. · William Rehnquist John P. Stevens · Sandra Day O'Connor
Case opinions
Majority	Stevens, joined by Brennan, White, Marshall, Blackmun
Concurrence	Brennan, joined by Marshall
Concurrence	O'Connor, joined by Burger, Powell, Rehnquist
Laws applied
Sherman Antitrust Act

Rationale

Any inquiry into the validity of a tying arrangement must focus on the market or markets in which the two products are sold, for that is where the anticompetitive forcing has its impact. Thus, in this case, the analysis of the tying issue must focus on the hospital's sale of services to its patients, rather than its contractual arrangements with the providers of anesthesiological services. In making that analysis, consideration must be given to whether petitioners are selling two separate products that may be tied together, and, if so, whether they have used their market power to force their patients to accept the tying arrangement.[1]

There is no evidence that the price, quality, or supply or demand for either the "tying product" or the "tied product" has been adversely affected by the exclusive contract, and no showing that the market as a whole has been affected at all by the contract.[1]

References

1. "Jefferson Parish Hosp. Dist. v. Hyde, 466 U.S. 2 (1984)". Justia Law.

External links

• Text of Jefferson Parish Hospital District No. 2 v. Hyde, 466 U.S. 2 (1984) is available from:  CourtListener  Findlaw  Google Scholar  Justia  Library of Congress  Oyez (oral argument audio)