Justia Contracts Opinion Summaries

PAMC appealed the district court's affirmance of the Secretary's decision denying PAMC its full Medicare Annual Payment Updated for the fiscal year 2009. PAMC claimed that the Department acted arbitrarily and capriciously when it refused to excuse PAMC's late filing of the required Reporting Hospital Quality Data for Annual Payment Updated (RHQDAPU) program data by the admittedly applicable deadline. The court concluded that PAMC neither pointed to any contrary or antithetical decisions by the Department under similar circumstances, nor otherwise demonstrated that the Board acted arbitrary or capriciously when it denied equitable relief. The court rejected PAMC's argument that the Board should have used the contract doctrine of substantial performance to excuse PAMC's failure to submit data at the proper time. The court did not view the Board's adherence to the policy of strict compliance with a deadline as arbitrary and capricious. Accordingly, the court affirmed the judgment of the district court. View "PAMC, LTD. v. Sebelius" on Justia Law

When Rita Licata was transferred to a nursing facility operated by Defendant Rita’s son Salvatore signed an agreement with the facility to arbitrate disputes arising from Rita’s stay at the facility. Salvatore signed the agreement in the space provided for the resident’s “authorized representative.” Rita suffered personal injuries at the nursing facility resulting in her death. Salvator filed a complaint as administrator of Rita’s estate against Defendant for, inter alia, wrongful death and negligence. Defendant filed a motion to dismiss the complaint and to compel arbitration. The motion judge denied the motion, concluding that Salvatore lacked authority to execute the arbitration agreement on Rita’s behalf. The Supreme Court affirmed, holding (1) Salvatore lacked authority to execute the agreement on Rita’s behalf; and (2) the arbitration agreement did not otherwise bind Rita’s estate. View "Licata v. GGNSC Malden Dexter LLC" on Justia Law

Barbara Johnson, in her capacity as her husband Dalton’s health care agent, signed an agreement with a nursing facility to arbitrate disputes arising from Dalton’s stay at the facility. While a resident of the facility, Dalton suffered burns and later died. The administrators of Dalton’s estate, filed a complaint against nursing home defendants and others, arguing that Barbara, as Dalton’s health care agent, did not have the authority to execute the arbitration agreement on his behalf. A superior court judge entered an order compelling mediation or arbitration. The Supreme Court vacated the order of the superior court, holding that a health care agent’s decision to enter into an arbitration agreement is not a health care decision under the health care proxy statute, and therefore, an agreement to arbitrate all claims arising out of a principal’s stay in a nursing facility does not bind the principal where the agreement was entered into solely by a health care agent under the authority of a health care proxy. View "Johnson v. Kindred Healthcare, Inc." on Justia Law

Dr. Adolfo P. Morales sued Jackson HMA, LLC., d/b/a Central Mississippi Medical Center (Jackson HMA) for breach of contract. A jury awarded Morales substantial damages. Jackson HMA filed a "Motion for Judgment Notwithstanding the Verdict, and, in the alternative, For a New Trial" and a "Motion for Amendment of Judgment." The Circuit Court denied the post-trial motions and Jackson HMA filed this appeal. In 2004, a recruiter for Jacksom HMA sent Morales a "letter of intent" outlining Jackson HMA's proposed offer. The letter twice stated that the proposed offer required "preapproval" by "Corporate" (HMA). Although not requested or provided for, Morales signed and returned the letter. On it he wrote "I agree to all and accept the terms of your offer." At trial, Morales acknowledged that this letter was not a contract, as it "no doubt" required preapproval from the corporate office. Subsequently, Jackson HMA sought approval from corporate HMA, but corporate did not approve the terms. Jackson HMA's CEO impressed upon corporate the need for an ophthalmologist and suggested new terms to corporate which reduced the guaranteed amount and period by half. The CEO received approval of these reduced terms from an HMA vice-president for the eastern part of the United States. Thereafter, the recruiter sent Morales a second letter detailing the new "terms of our offer" which reflected the reduced guarantees approved by corporate HMA. The letter lacked the phrase "letter of intent" and also made no reference to a requirement of corporate approval of the terms. The letter included the language, "[b]y signing and returning this letter, you will confirm your commitment to entering into a contractual agreement . . . . Accordingly we will begin the process of assimilating contract documents for your review." Morales signed the document, but approval never arrived. In early March 2005, the recruiter informed Morales that the contract had not been approved. In late 2005, Morales filed suit alleging that Jackson HMA had breached its contract with him. The jury returned a verdict in favor of Morales. Jackson HMA appealed. After its review, the Supreme Court concluded that Morales presented sufficient evidence for the jury to find that a contract existed. However, Morales presented insufficient evidence to support the jury's damages award. The Court affirmed the judgment for Dr. Morales, but reversed on the issue of damages and remanded this case to the Circuit Court for a new trial solely on damages. View "Jackson HMA, LLC v. Morales" on Justia Law

After discovering that she had lung cancer that had spread to her brain, Killian underwent aggressive treatment on the advice of her doctor. The treatment was unsuccessful and she died. Her husband submitted medical bills for the cost of the treatments to her health insurance company. The company denied coverage on most of the expenses because the provider was not covered by the insurance plan network. The husband filed suit, seeking benefits for incurred medical expenses, relief for breach of fiduciary duty, and statutory damages for failure to produce plan documents. The district court dismissed denial-of-benefits and breach-of-fiduciary-duty claims, but awarded minimal statutory damages against the plan administrator. In 2012, the Seventh Circuit affirmed the dismissals, rejecting an argument that the plan documents were in conflict, but remanded for recalculation of the statutory damages award. On rehearing, en banc, the Seventh Circuit affirmed the denial of benefits and statutory penalties holdings, but reversed on the breach of fiduciary duty claim. The instructions given in plan documents were deficient and a reasonable trier of fact could rule in favor of Killian, based on telephone conversations in which Killian attempt to determine whether the physicians who were about to perform surgery were within the network. View "Killian v. Concert Health Plan" on Justia Law

Appellee Steven Wilson is a licensed optometrist, providing eye care services in Lowndes County as Wilson Eye Center (“WEC”). Appellees Cynthia McMurray, Jodie E. Summers, and David Price are also licensed optometrists employed by WEC. Prior to 2010, Spectera, Inc. had entered provider contracts ("Patriot contracts") with Wilson and McMurray and they became members of Spectera's panel of eye care providers. Summers was already on Spectera's panel of eye care providers. Under the Patriot contract, Spectera would reimburse appellees for the materials Spectera insureds used from WEC's inventory by paying appellees a fee for their materials' costs and by having Spectera insureds remit a materials copayment to appellees. Spectera decided to terminate its Patriot contracts and replace them with independent participating provider (IPP) agreements. After the trial court temporarily enjoined Spectera from enforcing its IPP agreement, Spectera sought to remove appellees Wilson, Summers, and McMurray from its approved panel of providers. The trial court enjoined Spectera from taking such action. Although Price was not on Spectera's provider panel, he alleged Spectera violated Georgia law by denying him membership on its panel because of his refusal to sign the IPP agreement. Upon considering the parties' cross motions for summary judgment, the trial court granted issued a permanent injunction precluding Spectera from enforcing the restrictions contained in the IPP agreement as to "any other licensed eye care provider on [Spectera's] provider panel" or those who had applied for admittance to the panel. Spectera appealed the trial court's decision to the Court of Appeals which affirmed in part and reversed in part. Upon review of Spectera's appeal, the Supreme Court concluded a portion of the IPP agreement violated Georgia law, and therefore sustained the Court of Appeals in one respect. However, because the IPP agreement did create the type of impermissible discrimination between classes of licensed eye care providers contemplated by the applicable law, the Court of Appeals was incorrect in concluding that the IPP agreement violated that particular subsection of the applicable law. Furthermore, the termination of any outstanding contracts with appellees Wilson, McMurray, and Summers should have been based on the lawful terms stated in the contracts and not based on a permanent court injunction. Therefore, the Supreme Court affirmed in part, reversed in part and remanded the case for further proceedings. View "Spectera, Inc. v. Wilson" on Justia Law

Respondents in this case included Kaiser Foundation Health and Kaiser Foundation Hospitals (collectively, Kaiser). Michael Siopes, a public school teacher, enrolled in a Kaiser health plan offered through the Hawaii Employer-Union Health Benefits Trust Fund (EUTF). Michael was later diagnosed with cancer by a Kaiser medical professional. Michael and his wife, Lacey, subsequently consulted a medical team at Duke University Medical Center. The Duke team determined that Kaiser's diagnosis was erroneous and recommended a different treatment plan. Michael received treatment at Duke that was ultimately successful. Kaiser denied Michael's request for coverage. Michael and Lacey sued Kaiser for, among other things, breach of contract and medical malpractice. Kaiser filed a motion to compel arbitration, arguing that a group agreement entered into Kaiser and the EUTF was applicable to Michael when he signed the enrollment form. The group agreement contained an arbitration provision. The circuit court granted the motion to compel arbitration. The Supreme Court vacated the circuit court's orders, holding (1) the arbitration provision was unenforceable based on the lack of an underlying agreement between Kaiser and Michael to arbitrate; and (2) accordingly, Lacey was also not bound to arbitrate her claims in this case. View "Siopes v. Kaiser Found. Health Plan, Inc." on Justia Law

Health and Hospital Corporation of Marion County, Indiana is a municipal corporation that operates a major hospital and other facilities, including a health center operated in partnership with Citizens Health to serve the medically under-served population in Indianapolis. The health center was funded in part by a Section 330 Grant, awarded by the federal Health Resources and Services Administration, which is part of the Department of Health and Human Services. Section 330 grants fund qualifying health centers that provide primary health care services to medically under-served populations, 42 U.S.C. 254b. A In 2012, Health and Hospital decided to terminate the partnership with Citizens and relinquish the federal grant, which still had several years of funding remaining. Citizens sued Health and Hospital, HRS, and others in an effort to retain the grant funds. The district court granted defendants summary judgment, concluding that Citizens had no contractual, statutory, or constitutionally cognizable interest in the grant. The Seventh Circuit affirmed, finding that Health and Hospital was the grantee; Citizens had no constitutionally-protected entitlement to the grant; and the terms of the contract between Health and Hospital and Citizens clear; there was no obligation to renew. View "Citizens Health Corp. v. Sebelius" on Justia Law

Plaintiff-Appellant John Schmitt appealed the dismissal of his claims against MeritCare Health System for defamation, tortious interference with a prospective business advantage, and violation of state antitrust law. Upon review, the Supreme Court concluded that Plaintiff's allegations lacked merit, and affirmed the grant of summary judgment dismissing his claims. View "Schmitt v. MeritCare Health System" on Justia Law

The Fund is a multi-employer trust fund under the Taft-Hartley Act, 29 U.S.C. 186, and the Employee Retirement Income Security Act, 29 U.S.C. 1001. Blue Cross is a Michigan non-profit corporation; its enabling statute authorizes the State Insurance Commissioner to require it to pay a cost transfer of one percent of its “earned subscription income” to the state for use to pay costs beyond what Medicare covers. In 2002 the Fund converted to a self-funded plan, and entered into an Administrative Services Contract with Blue Cross, which states that Blue Cross is not the Plan Administrator, Plan Sponsor, or fiduciary under ERISA; its obligations are limited to processing and paying claims. In 2004 the Fund sued, claiming that Blue Cross breached ERISA fiduciary duties by imposing and failing to disclose a cost transfer subsidy fee to subsidize coverage for non-group clients. The fee was regularly collected from group clients. Self-insured clients were not always required to pay it. Following a first remand, the district court granted class certification and granted the Fund summary judgment. On a second remand, the court again granted judgment on the fee imposition claim and awarded damages of $284,970.84 plus $106,960.78 in prejudgment interest. The Sixth Circuit affirmed. View "Pipefitters Local 636 Ins. Fund v. Blue Cross & Blue Shield of MI" on Justia Law