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Vázquez-Ramos v. Triple-S Salud, Inc. — 1st Cir. (Nov 4, 2026)

No. 25-1783 Argued November 4, 2026 Published November 6, 2026

The First Circuit hears Vázquez-Ramos versus Triple-S Salud, a dispute over access to urology care under a government health plan in western Puerto Rico. Several doctors and their practices say the insurer replaced their network contracts with an exclusive arrangement involving a competing provider. They contend that this not only cost them business, but also restricted patients' choice of doctors and access to care. The insurer and the competing providers will answer that the arrangement resulted from competition for the contract, lowered costs, and did not reduce care. An earlier appeal allowed part of the lawsuit to go forward; it did not establish an antitrust violation. After discovery, the district court granted summary judgment for the defendants, finding the record insufficient to send the claims to trial. The doctors now challenge that ruling. Two distinctions help explain the questions that follow. First, antitrust law protects competition, not simply an individual competitor's income. An excluded competitor can be the right plaintiff when its loss flows from the allegedly competition-reducing conduct. That is the issue of antitrust injury: whether this is the kind of loss the antitrust laws address. It is distinct from ultimately proving that the challenged arrangement unlawfully harmed competition. Second, an exclusive contract is not automatically illegal. Under the rule of reason, the competitive effects matter, including whether patients faced reduced services or poorer access rather than genuine efficiencies. The doctors will argue that the evidence supports a trial; the defendants will dispute what the record shows about harm across the relevant market. Before those merits questions, listen for a procedural issue: did the doctors sufficiently challenge the separate antitrust-injury ruling in their opening appellate brief? Do not confuse that question about preserving an argument with a decision on whether patients actually received worse care. As you listen, keep the doctors' lost business, the type of injury they allege, and the evidence about competition and patient care separate.

Vázquez-Ramos v. Triple-S Salud, Inc. (No. 25-1783) — U.S. Court of Appeals for the First Circuit, argued November 4, 2026.

Sources
Argument audio — official First Circuit recording:https://www.ca1.uscourts.gov/sites/ca1/files/oralargs/25-1783_20261104.mp3
Case and argument date — official First Circuit archive:https://www.ca1.uscourts.gov/doar/results/2026-11
Ruling under appeal — DPR Doc 255, Jul 15, 2025; verified court-authored copy:https://business.cch.com/ald/RamosvTripleSSaludInc7182025.pdf
Earlier appeal — First Circuit 21-1115, Dec 8, 2022; pleading-stage ruling, not this appeal's outcome:https://www.ca1.uscourts.gov/sites/ca1/files/opnfiles/21-1115P-01A.pdf
Defendants' economic expert — firsthand firm account, Jul 28, 2025; interested defense account, not a neutral finding:https://secretariat-intl.com/insights/jason-albert-puerto-rico-healthcare-antitrust/

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