The State Action Doctrine Pursuant to the “State Action Doctrine,” however, Sheriff Waters may be absolutely immune from both money damages and injunctive relief. Under the State Action Doctrine, courts hold that federal antitrust laws are not intended to prohibit States from imposing restraints on competition; thus, a State itself is absolutely immune from antitrust actions, both for money damages and for injunctive relief. See Parker v. Brown, 317 U.S. 341, 63 S.Ct. 307, 87 L.Ed. 315 (1943); Cohn, 953 F.2d at 158. A lawsuit brought directly against state officials, when they are acting in their official capacities, cannot circumvent the immunity given to the State itself as a sovereign. See Earl W. Kintner and Joseph P. Bauer, Federal Antitrust Law, § 76.6; c.f. Cohn, 953 F.2d at 158 (<HOLDING>). Thus, to the extent that plaintiff seeks to
holding that where hospital used balance billing that since the hospital had already received payments from the patient and his health insurer and had agreed to accept that amount as payment in full for its services there was no longer any amount owing to the hospital and thus it could not assert a statutory hospital lien for the difference between its charges and the amount received in light of the negotiated network agreements holding that physicians as agents of the hospital are indistinguishable from the hospital for immunity purposes under the lgaa holding that because the trial court did not abuse its discretion in finding the expert report adequate as to the vicarious liability claim against the hospital based on the actions of the doctors plaintiffs suit against the hospital including her claim that the hospital was vicariously hable for the actions of its nurses could proceed holding that because the contract between the hospital and the health insurance company had a hold harmless provision which stated the hospital would not bill or hold insurance subscribers liable for any hospital expenses covered by the subscribers insurance contract and all expenses from the patients treatment for the automobile accident were covered in such contract there was no debt upon which the hospital could assert a lien pursuant to the states hospital lien statute holding that expert reports were not required to mention the defendant hospital because reports were based upon the actions of hospital physicians