A federal trial court has dismissed a lawsuit filed by several independent clinical laboratories in California accusing Quest Diagnostics of conspiring with large health insurers to exclude competing labs from in-network designation (Rheumatology Diagnostics Laboratory Inc. v. Aetna Inc., N.D. Cal., No. 3:12-cv-5847, 6/25/13). The U.S. District Court for the Northern District of California said claims filed by Rheumatology Diagnostics Laboratory Inc. and other excluded laboratories, which alleged the conspiracy was designed to drive competing labs out of business, failed to plausibly allege that the defendants conspired to restrain trade or that Quest monopolized the relevant markets in violation of the Sherman Act or California’s Cartwright Act. The court specifically found allegations of a conspiracy among the defendants were inadequate and that claims that defendants engaged in an unreasonable restraint of trade or were monopolizing or attempting to monopolize the laboratory services market were not adequately supported. Judge Jon S. Tigar granted the defendants’ motions and dismissed the plaintiffs’ complaint with leave to replead. Challenged Conduct Rheumatology Diagnostics Laboratory Inc., Pacific Breast Pathology Medical Corp., Hunter Laboratories LLC, and Surgical Pathology Associates sued Blue Shield of California Life & Health Insurance Co. (BSC), Blue Cross and Blue Shield Association (BCBSA),…
