Capitol Radiology LLC v. University of Maryland Medical System, 8:24-cv-02548

Capitol Radiology, an African American-owned radiology facility, filed suit after the University of Maryland Medical System (UMMS) and RadNet, through a joint venture, contracted to build an outpatient radiology center next to Capitol Radiology's Laurel, Maryland location.
Capitol Radiology alleged the defendants improperly excluded it from the bidding process for outpatient imaging services, violating Maryland procurement and anti-discrimination statutes, as well as federal and state antitrust, equal protection, and contract laws.
The Asset Purchase Agreement, relevant to the dispute, gave Capitol Radiology an exclusive negotiation right for future MRI services, which Capitol contended was breached.
Defendants moved to dismiss under Rule 12(b)(6), arguing no plausible claims were stated, no private right of action existed for the cited Maryland statutes, insufficient facts of discrimination, antitrust injury, or contract liability were alleged.
The Court granted all defendants’ motions to dismiss, holding the complaint failed to plausibly state any claims and that Maryland statutes at issue do not provide a private right of action.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Md. Code Ann., Educ. § 13-303(e)&(d) provide a private right of action	Statutes confer rights allowing Capitol to sue for procurement and discrimination violations	Statutes provide only general directives to UMMS Board, no private right of action	No private right of action; claims dismissed
Whether exclusion from bidding/Joint Venture was unlawful discrimination	Exclusion based on race/sex violated equal protection and anti-discrimination laws	No sufficient facts of intentional discrimination or that private actors were state actors	Claims dismissed, no intentional discrimination alleged, private actors not state actors
Whether the Asset Purchase Agreement was breached or tortiously interfered with	RadNet breached contract; UMMS tortiously interfered with negotiation rights	RadNet not party to the contract; no evidence UMMS/UM Capital knew of, or interfered with, contract	Breach and interference claims dismissed
Whether antitrust claims are plausible under federal/state law	Joint Venture harmed competition, created monopoly & harmed Capitol's business	No plausible relevant market, restraint of trade, or antitrust injury alleged; harm speculative	Antitrust claims dismissed for lack of plausibility and injury

Ashcroft v. Iqbal, 556 U.S. 662 (standards for plausibility under Rule 12(b)(6))
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading requirements for antitrust and plausible claims)
Brunswick Corp. v. Pueblo Bowl-O-Mat, Inc., 429 U.S. 477 (defines antitrust injury necessary for private standing)
Lugar v. Edmondson Oil Co., Inc., 457 U.S. 922 (state action requirement for constitutional claims)
Will v. Michigan Dept. of State Police, 491 U.S. 58 (sovereign immunity of state entities)
Manhattan Cmty. Access Corp. v. Halleck, 587 U.S. 802 (private entity not transformed into state actor by government contract)
Village of Arlington Heights v. Metropolitan Hous. Dev. Corp., 429 U.S. 252 (pleading standards for intentional discrimination)