Spectera, Inc.v.Steven Wilson
Spectera, a vision-care insurer, replaced legacy contracts held by independent Georgia optometrists with an agreement requiring them to obtain eyeglasses and contact lenses from Spectera’s laboratory. Independent providers challenged the restriction under Georgia’s Patient Access to Eye Care Act, and the trial court granted summary judgment and injunctive relief in their favor. The Georgia Court of Appeals held, in a first-impression decision, that the materials requirement violated the Act because it prevented independent optometrists from providing services within their licenses while retail-chain providers retained that ability. The same restriction also unlawfully conditioned an applicant’s admission to the provider panel when refusal to sign it was the only reason for exclusion. The court rejected the claim that the agreement violated the Act’s prohibition on promoting one provider class over another because the record did not show that Spectera presented retail providers to plan members through advertising or recommendation. The court upheld an injunction against Spectera as to the independent optometrists and could reach other optometrists on the panel because the injunction bound only Spectera, but reversed the injunction insofar as it covered independent providers or applicants outside the optometrist class. The judgment was affirmed in part and reversed in part.
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