Antitrust Law Daily Wrap Up, ANTITRUST—E.D. Tex.: Federal court denies preliminary injunction against CRNAs' noncompete agreements, citing Anti-Injunction Act, (Apr 10, 2026)

By Wendy Biddle, J.D.

The plaintiffs failed to demonstrate irreparable harm and that federal intervention would improperly interfere with state court proceedings already underway.

The federal court in Beaumont, Texas denied a motion for preliminary injunction filed by seven Certified Registered Nurse Anesthetists seeking to void noncompete agreements with their former employer, Anesthesia Associates. The court ruled that the nurses failed to satisfy the requirements for extraordinary preliminary relief and that the Anti-Injunction Act barred federal courts from interfering with ongoing state court proceedings (Bentzen v. Anesthesia Associates, PA, No. 1:25-cv-00568-MAC (E.D. Tex. Apr. 8, 2026)).

Background. The dispute arose from Anesthesia Associates' decision to terminate its contract with CHRISTUS St. Elizabeth Hospital in Beaumont, Texas. AA, a physician-owned medical group employing anesthesiologists and CRNAs, had entered into a three-year contract with CHRISTUS in September 2024 to provide anesthesia services at facilities in Jefferson County, including St. Elizabeth Hospital.

In early 2025, AA determined its St. Elizabeth contract was insufficiently profitable after two physician groups ceased their affiliation with the hospital to open independent surgical centers. On March 31, 2025, AA formally notified CHRISTUS it was terminating the contract effective August 1, 2025, stating the contract terms no longer aligned with financial realities and seeking to negotiate more favorable compensation.

When negotiations reached an impasse, CHRISTUS signed a contract with EmergencHealth to begin providing anesthesia services on August 1, 2025. The seven plaintiff CRNAs, who had been employed by AA for periods ranging from four to thirteen years and regularly practiced at St. Elizabeth, subsequently applied for and accepted positions with EmergencHealth to continue working at the hospital.

All plaintiffs had signed identical employment agreements with AA containing restrictive covenants prohibiting them from providing CRNA services for three years within a 20-mile radius of any facility where they provided services while employed by AA. The agreements also included liquidated damages clauses establishing a $30,000 penalty for breach of the noncompete provision.

Despite evidence that EmergencHealth offered to pay AA the $30,000 liquidated damages for each CRNA, AA refused and instead demanded $400,000 per CRNA to drop its enforcement efforts. AA filed two separate state court actions in Jefferson County seeking to enjoin the plaintiffs from providing anesthesia services within the restricted geographic area. The state courts granted temporary injunctions in September and October 2025, finding the noncompete covenants valid and enforceable under Texas law.

The plaintiffs subsequently filed their federal action on December 3, 2025, asserting claims under Section 1 and Section 2 of the Sherman Act and corresponding provisions of the Texas Free Enterprise and Antitrust Act. They sought damages and injunctive relief, moving for a preliminary injunction on December 19, 2025.

Preliminary injunction. The court evaluated the motion under the four-factor test established in Winter v. Natural Resources Defense Council: likelihood of success on the merits, substantial threat of irreparable harm, balance of equities, and public interest. The court noted that preliminary injunctions constitute extraordinary remedies treated as exceptions rather than the rule.

Likelihood of success on the merits. The court found plaintiffs' likelihood of success uncertain on their antitrust claims. While acknowledging that the employment agreements between AA and the CRNAs satisfied the concerted action requirement for a Section 1 conspiracy claim, the court expressed doubt about whether plaintiffs could establish substantial anticompetitive effects under the rule of reason standard.

The court agreed that AA possessed significant market power over CRNA services in Jefferson County but found the evidence mixed on whether this dominance created anticompetitive barriers to entry. While EmergencHealth struggled to find sufficient CRNA labor to meet St. Elizabeth's capacity needs, the court noted that AA's hospital contracts were not exclusive and nothing prevented competitors from recruiting CRNAs not bound by noncompete agreements.

On the monopolization claims under Section 2, the court found insufficient evidence that AA used its market power to foreclose competition, gain competitive advantage, or destroy competitors. The court attributed EmergencHealth's need to hire expensive temporary CRNAs primarily to a nationwide shortage of CRNAs rather than intentional anticompetitive conduct by AA.

The court also determined that the Anti-Injunction Act barred the requested relief regardless of the merits. The statute prohibits federal courts from enjoining state court proceedings except in three narrow circumstances, none of which applied. The court reasoned that granting preliminary relief would place its order in direct conflict with the state court injunctions, creating precisely the federal-state friction the Act was designed to prevent.

Irreparable harm. The court rejected plaintiffs' argument that inability to practice their chosen profession in Jefferson County constituted irreparable harm. The court distinguished the case from precedents involving complete professional exclusion, noting that the noncompete clauses did not categorically bar plaintiffs from providing CRNA services altogether but only restricted them geographically for a limited three-year period.

The court found plaintiffs could still feasibly live in Jefferson County while traveling to surrounding cities like Houston, Baytown, and Lake Charles to practice as CRNAs. Additionally, all plaintiffs continued receiving substantial salaries of approximately $320,000 annually from EmergencHealth despite potentially working reduced hours or outside the restricted radius.

The court determined that any financial losses would be compensable through monetary damages at trial, noting that temporary loss of income ultimately to be recovered does not constitute irreparable injury under Fifth Circuit precedent. The court also found plaintiffs' concerns about family disruption, commuting difficulties, and missing children's activities to be speculative harms not cognizable under the Sherman Act, which does not provide for emotional damages.

The court noted that plaintiffs' four-month delay between the state court injunctions and filing their federal motion undermined claims of immediate irreparable harm. The court suggested this timing indicated an attempt to obtain a second opportunity for relief after the state court ruled against them.

Balance of equities and public interest. The court found the balance of equities favored AA, reasoning that granting preliminary relief would effectively invalidate the noncompete agreements and create substantial risk that AA would lose its CRNA workforce, rendering it unable to meet existing contractual obligations and threatening its business survival. In contrast, the court had already determined plaintiffs failed to demonstrate irreparable harm.

However, the public interest factor weighed in favor of plaintiffs. The court acknowledged that St. Elizabeth, as Jefferson County's only Level III trauma center, faced reduced surgical capacity due to inadequate CRNA staffing. Evidence showed the hospital could not open all available operating rooms and had restricted its surgery schedule, potentially delaying emergency care and compromising public safety.

Despite finding the public interest factor favored plaintiffs, the court concluded that the other three preliminary injunction factors weighed against granting relief. The court emphasized that the Anti-Injunction Act independently precluded federal intervention where the requested injunction would directly conflict with state court orders. The motion for preliminary injunction was denied, leaving the state court injunctions in place and the antitrust claims to proceed to trial on the merits.

The Case is No. 1:25-cv-00568-MAC.

Judge: Crone, M.

Attorneys: Jennifer Fleury (Hogan Lovells US LLP) for Monica Bentzen. John Gerard Werner (Reaud Morgan & Quinn LLP) for Anesthesia Associates, PA and Anesthesia Associates Group, PLLC.

Companies: Anesthesia Associates, PA; Anesthesia Associates Group, PLLC

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