Federal Appeals Court Rules Hospital But Not Physicians’ Practice Immune From Unfair Competition Claims

A federal appeals court upheld a district court ruling that Westchester County Health Care Corporation, a public benefit corporation created by the state of New York that operates Westchester Medical Center in Valhalla, N.Y., is immune from unfair competition claims brought forth by two cardiothoracic surgeons, whose privileges were revoked following an exclusive agreement by the hospital with a competing practice, New York Cardiothoracic Group.

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The appeals court ruled that WCHCC is entitled to the same status as a municipality under the state action immunity analysis, which provides the corporation immunity from unfair competition claims.

The court ruled that the same status was not granted to New York Cardiothoracic Group and remanded the case back to the district court for further proceedings.

Read the federal appeals court ruling (pdf).

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