Tafford E. Oltz v. St. Peter's Community Hospital, Tafford E. Oltz v. St. Peter's Community Hospital

This case concerns a Sherman Act § 1 claim for damages from an unlawful conspiracy among anesthesia service providers and the local hospital to enter an exclusive dealing contract and eliminate competition. By special verdict in a bifurcated trial, the jury found the defendant hospital liable and awarded damages of $421,831. The district court denied the hospital’s motion for judgment notwithstanding the verdict or for a new trial on the issue of liability. Sua sponte, however, the district court ordered a new trial on damages after finding that the damages awarded were excessive. Defendant hospital challenges jury instructions, the jury’s special verdict on liability, and the denial of the post-trial motion. Plaintiff challenges the order granting a new trial on damages. We affirm both orders of the district court.

FACTUAL BACKGROUND

Defendant St. Peter’s Community Hospital (“St. Peter’s”) is one of two hospitals in Helena, one of Montana’s smaller cities. St. Peter’s, however, is the only hospital in the area open to the general public and equipped to perform general surgery. At trial, the parties stipulated that St. Peter’s enjoys a market share of 84% of general surgical…