Case Citator › Jefferson Parish Hospital District No. 2 v. Hyde

Jefferson Parish Hospital District No. 2 v. Hyde

Is it still good law? What later courts have actually done to this case.

Abrogated
Court
Supreme Court of the United States
Citation
466 U.S. 2
Decided
Confirmed treatments
2
Flagged citations read
75 of 75
Citing cases (total)
891
Treatment dates
2001–2006
Abrogated
A reviewed court treats this case as abrogated by later authority. Jefferson Parish Hospital District No. 2 v. Hyde has been abrogated in part. All 75 flagged citations have been read.
More on how this was screened

The Supreme Court abrogated its patent-market-power presumption in Illinois Tool Works Inc. v. Independent Ink, Inc.; the D.C. Circuit limited use of its per se tying framework for platform software. Both confirmed treatments are listed below. Jefferson Parish’s general market-power requirement remains part of tying analysis.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

891 later cases cite Jefferson Parish Hospital District No. 2 v. Hyde; 75 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Jefferson Parish Hospital District No. 2 v. Hyde?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Abrogated

  • The Court abrogated Jefferson Parish’s patent-market-power presumption and required proof of market power for tying claims involving a patented product.

    Illinois Tool Works Inc. v. Independent Ink, Inc. · Supreme Court of the United States · filed

    In Jefferson Parish Hospital Dist. No. 2 v. Hyde, 466 U. S. 2 (1984), we repeated the well-settled proposition that “if the Government has granted the seller a patent or similar monopoly over a product, it is fair to presume that the inability to buy the product elsewhere gives the seller market power.” ... that conclusion must be supported by proof of power in the relevant market rather than by a mere presumption thereof.
    Read the full opinion on CourtListener →

Limited

  • The D.C. Circuit confined Jefferson Parish's per se tying framework for platform software, vacated per se liability, and required rule-of-reason review.

    United States v. Microsoft Corp. · D.C. Circuit · filed

    We hold that the rule of reason, rather than per se analysis, should govern the legality of tying arrangements involving platform software products. ... Jefferson Parish, 466 U.S. at 9 (emphasis added). But there are strong reasons to doubt that the integration of additional software functionality into an OS falls among these arrangements.
    Read the full opinion on CourtListener →

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