Justia Contracts Opinion Summaries

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

At issue before the Supreme Court was an Asset Purchase Agreement. Portsmouth Regional Hospital was sold to the Hospital Corporation of America. A dispute arose over the meaning of certain terms and clauses in the purchase agreement. The Foundation for Seacoast Health sought to "repurchase" the hospital's tangible assets under certain conditions. The dispute arose when the Foundation sought to assert that right. The Foundation appealed the trial court’s determination that the clause under dispute in this case was intended to give the Foundation a right to purchase the Hospital only in the event of a sale to a third party. The Foundation argued that because of this error, the trial court also erred by failing to: (1) order specific performance of the Foundation’s contractual right to purchase the Hospital; (2) award monetary damages for the defendants’ material breach; and (3) award attorney’s fees for the remedy proceeding. Upon review of the contract in question, the Supreme Court affirmed all but the trial court’s attorney’s fee award. View "Foundation for Seacoast Health v. Hospital Corporation of America" on Justia Law

Appellant received treatment at Hospital for injuries she sustained in an automobile accident. Appellant granted two statutory liens to Hospital on settlement proceeds she obtained from the tortfeasor for hospital services rendered. Appellant subsequently settled her case against the tortfeasor, and the tortfeasor's insurer (Insurer) agreed to pay Appellant $1.3 million in exchange for Appellant's agreement to indemnify Insurer from all healthcare provider liens. Hospital subsequently sued Insurer, and Appellant tendered to Hospital all money it asserted was due. Appellant then filed a complaint against Hospital, alleging that Hospital overcharged her pursuant to Nev. Rev. Stat. 439B.260(1), which provides that hospitals must reduce charges by thirty percent to inpatients who lack insurance "or other contractual provision for the payment of the charge by a third party." The district court entered judgment in favor of Hospital, finding that Appellant's settlement agreement with the tortfeasor rendered Appellant ineligible for the thirty percent statutory discount. The Supreme Court reversed in part, holding that a patient's eligibility is determined at the commencement of hospital services, and therefore, a later settlement agreement with a third party for the payment of such services does not disqualify the patient for the statutory discount. View " Bielar v. Washoe Health Sys., Inc." on Justia Law

The family of a nursing home patient filed this action against the nursing home for, inter alia, medical negligence, negligence per se, breach of contract, and retaliation. Plaintiffs asserted the retaliation claim under the Texas Health & Safety Code, which creates a cause of action against a nursing facility that retaliates against a resident or family member who makes a complaint concerning the facility. Defendants moved to dismiss all of the claims pursuant to the Texas Medical Liability Act (TMLA) because the expert report was deficient. The trial court dismissed all of Plaintiffs' claims except for the retaliation claim, concluding that the claim was not a health care liability claim (HCLC) for which the TMLA requires a supporting expert report. The court of appeals affirmed. The Supreme Court reversed the court of appeals' judgment with respect to the retaliation claim, holding that because the retaliation claim was based on the same factual allegations on which one of Plaintiffs' HCLCs was based, the claim should have been dismissed for lack of a sufficient expert report. View "PM Management-Trinity NC, LLC v. Kumets" on Justia Law

Decedent became a resident of Golden Living Center, a nursing home, in 2009. Later that year, Courtyard Gardens took over ownership and operation of the facility. Thereafter, Decedent's son, Ronald Quarles signed a new admission agreement and optional arbitration agreement. In 2011, Kenny Quarles, another of Decedent's sons acting as power of attorney, filed an amended complaint against Courtyard Gardens and other entities associated with it and the Center, seeking damages for negligence, medical malpractice, and violations of the Arkansas Long-Term Care Residents' Act. Courtyard Gardens filed a motion to dismiss and compel arbitration. The circuit court denied Courtyard Garden's motion to compel arbitration, concluding that questions of fact remained regarding Ronald's authority to bind Decedent to the arbitration agreement. The Supreme Court affirmed the denial of the motion to compel arbitration, holding that there was no valid arbitration agreement as a matter of law because Ronald had neither actual authority nor statutory authority to enter into the arbitration agreement on Decedent's behalf. View "Courtyard Gardens Health & Rehab., LLC v. Quarles" on Justia Law

Several hospitals (Hospitals) sued Aetna, Inc. and Aetna Health, Inc. (collectively Aetna) for allegedly violating the Prompt Pay Statute. Aetna provided a Medicare plan (Plan) through an HMO called NYLCare. It delegated the administration of its Plan to North American Medical Management of Texas (NAMM), a third-party administrator. IPA Management Services (Management Services) provided medical services to Plan enrollees. Management Services entered into contracts with the Hospitals to secure hospital services for the Plan employees. Aetna was not a party to these contracts. The Hospitals submitted hospital bills to NAMM for payment. After NAMM and Management Services became insolvent, Aetna de-delegated NAMM and assumed responsibility for processing and paying claims. However, Aetna instructed the Hospitals to continue submitting their bills to NAMM. The Hospitals argued that Aetna was liable for NAMM's failure to timely pay claims and was responsible for $13 million in outstanding bills. The trial court granted summary judgment for Aetna. The court of appeals affirmed, concluding that because the Hospitals entered into contracts with Management Services and not with Aetna directly, the Hospitals had no viable prompt-pay claim. The Supreme Court affirmed, holding that the lack of privity between the Hospitals and Aetna precluded the Hospitals' suit. View "Christus Health Gulf Coast v. Aetna, Inc." on Justia Law

The Doctors Company (TDC), a professional liability insurance company, sought a determination that its coverage of policyholder Women's Healthcare Associates (WHA) did not apply to a pending breach of contract action relating to WHA's participation in the Virginia Birth-Related Neurological Injury Compensation Act (the Birth Injury Fund). The Davidson family filed the underlying breach of contract action against WHA, alleging that they entered into an express contract with WHA partly in reliance on WHA's participation in the Birth Injury Fund, and WHA materially breached the contract by failing to pay into the fund as represented to the Davidsons. The circuit court ruled against TDC and in favor of WHA and the Davidsons, finding that the policy covered the claim alleged by the Davidsons in their complaint against WHA. The Supreme Court affirmed, holding (1) the underlying action was covered by the insurance policy; and (2) therefore, TDC must both defend and indemnify WHA in the underling breach of contract action. View "The Doctors Co. v. Women's Healthcare Assocs." on Justia Law

Appellant Altrua HealthShare appealed the district court's decision affirming the Idaho Department of Insurance's (Department) determination that Altrua transacted insurance without a certificate of authority. Altrua argued that both the Department and the Ada County district court erred in finding that Altrua was an insurer because Altrua never assumed the risk of paying its members' medical bills. The Department found, and the district court affirmed, that when members make their predetermined monthly payments into the escrow account Altrua operates, the risk of payment shifts from the individual members to the escrow account, and in turn to Altrua. Altrua also contended that the Department's determination that it is an insurer despite the disclaimers in its membership contract to the contrary is an unconstitutional interference with Altrua's right to contract. Upon review, the Supreme Court found that the Department's conclusion that Altrua's membership contract was an insurance contract was clearly erroneous, and reversed the findings. The case was remanded for further proceedings. View "Altrua Healthshare v. Deal" on Justia Law