First Circuit Dismisses Antitrust Claims Against Three HMOs, Holding Them Incapable of Collusion

In Gonzalez-Maldonado et al v. MMM Health Care Inc. et al., the First Circuit Court of Appeals rejected antitrust claims filed by two Puerto Rico doctors against three HMOs, which cut ties with the doctors over disputed payments.  In dismissing the antitrust claims, the court held that the three HMOs are incapable of collusion because they all share the same corporate parent — MMM Holdings Inc. — making them “a single economic unit” that has a “complete unity of interest” and cannot violate the Sherman Act’s conspiracy prohibition.

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