Adam Biegel was quoted in a Global Competition Review article discussing the FTC’s recent loss of an appeal involving its challenge to a hospital merger in Georgia, which had been rejected by a federal district court based on state action immunity. “The state action doctrine has various twists and turns depending on the statutes and activities involved, and this won’t be the last challenge to invocation of such protection brought by the FTC,” he said. “But having another appellate decision affirming immunity will encourage both hospitals and other entities concerned about antitrust risks to explore reasonable paths to reach similar results.”