In the 1983 case Jefferson Parish Hospital District No. 2 et al. v. Hyde, anesthesiologist Edwin G. Hyde challenged a contractual agreement between East Jefferson General Hospital and Roux & Associates, which required all surgical patients at the hospital to use Roux's anesthesia services unless specifically exempted by the surgeon performing their procedure. Hyde argued that this "tying" arrangement violated Section 1 of the Sherman Antitrust Act as it limited competition in providing anesthesia services at East Jefferson General Hospital. The U.S Supreme Court ruled in favor of the hospital district and against Dr.Hyde with a majority vote of 6-3, stating that while such arrangements could potentially be anti-competitive under certain circumstances, they were not inherently illegal under antitrust laws unless there was sufficient market power to restrain trade appreciably - something which had not been demonstrated in this particular case.

In the dissenting opinion for Jefferson Parish Hospital District No. 2 et al. v. Hyde, Justice O'Connor disagreed with the majority's application of antitrust laws to this case, arguing that it was too broad and could potentially stifle legitimate business practices in a competitive market environment. She argued that tying arrangements should only be considered illegal if they have an actual adverse effect on competition or are likely to do so due to significant market power held by the seller of the tying product - conditions she did not believe were met in this case. Furthermore, she criticized the majority's reliance on perceived coercion as evidence of anti-competitive behavior, stating that such perceptions may simply reflect strong consumer demand for bundled products rather than any coercive tactics employed by sellers.