The Third Circuit reversed the dismissal of a Section 1 claim brought by West Penn Allegheny Health Systems, Inc. against the University of Pennsylvania Medical Center (UPMC). West Penn alleged that UPMC used its power in the health care provider market to protect Highmark, an insurance carrier, from competition. In exchange, the plaintiffs allege that Highmark used its power in the insurance market to protect UPMC from competition.
The appellate court rejected the lower court’s belief that judges act as the gatekeepers in overseeing antitrust suits, subjecting plaintiffs to a heightened pleading standard. Instead, the court held that Bell Atlantic v. Twombly, and Ashcroft v. Iqbal retained Rule 8’s traditional standard regardless of the complexity of the case.