Justia Contracts Opinion Summaries

The Supreme Court dismissed this interlocutory appeal of a vacated class certification order and directed the circuit court to remand the case to address motions to compel arbitration, holding that this appeal was moot.Plaintiffs, who represented the estates of former residents of fourteen different nursing homes, alleged breach of contract and unjust enrichment claims against the nursing homes, in violation of the Arkansas Civil Rights act and the Arkansas Deceptive Trade Practices Act. The nursing homes moved to compel arbitration for all but two of the named plaintiffs, after which the plaintiffs moved for class certification. The circuit court granted Plaintiffs' motion for class certification without ruling on the motions to compel arbitration. The nursing homes brought an interlocutory appeal of the class-certification order and petitioned for writ of prohibition, mandamus, and certiorari. The Supreme Court granted the writ petition, vacating the order granting class certification, and ordered the circuit court to rule on the motions to compel before ruling on class certification, holding that the interlocutory appeal of the vacated class-certification order was moot. View "Reliance Health Care, Inc. v. Mitchell" on Justia Law

In this action arising out of the curtailment of classes and services at the University of Rhode Island (URI) during the COVID-19 pandemic, the First Circuit affirmed the judgment of the district court dismissing some of Plaintiffs' claims early in the litigation and granting summary judgment in favor of Defendant on the remaining claims, holding that the district court did not err.Plaintiffs, students who remained enrolled at URI during the pandemic, filed separate putative class actions against URI alleging breach of contract and unjust enrichment. Specifically, Plaintiffs argued that URI had breached its contract when it stopped providing in-person, on-campus instruction. The district court dismissed certain claims and then, following the completion of discovery, granted summary judgment on the remaining claims. The First Circuit affirmed, holding that Plaintiffs failed to make out a genuine issue of material fact as to whether URI had either an express or implied contract to provide in-person services and activities. View "Burt v. Bd. of Trustees of University of R.I." on Justia Law

The insurer, in this case, had notice of the hospital’s lien for treatment provided to the patient and, pursuant to a settlement agreement with the patient, gave him a check for the lien amount made payable to both him and the hospital. The hospital, Long Beach Memorial Medical Center, claims this action did not comply with the Hospital Lien Act (HLA) and sued the insurer who wrote the check, Allstate Insurance Company, for violating the HLA. The trial court granted Allstate’s motion for summary judgment, ruling Allstate’s two-payee check, which was never cashed, satisfied its obligation under the HLA.   The Second Appellate District reversed. The court concluded that merely delivering to the patient (or, in this case, his attorney) a check for the lien amount, made payable to both the patient and the hospital, is not a payment in satisfaction of the hospital’s lien under the HLA. The court explained Allstate maintains that it made this payment to the Medical Center concurrent with payment to the patient and that, therefore, the Medical Center cannot establish Allstate made a settlement payment to the patient without paying the Medical Center the amount of its lien. The court explained that Allstate declined to specify which check made payable to the Medical Center as copayee—the February 2020 check or the March 2021 check— Allstate claims satisfied its payment obligation to the Medical Center. However, neither check was a payment to the Medical Center. Moreover, Allstate does not invoke the exception to the general rule here. View "Long Beach Memorial Medical Center v. Allstate Ins. Co." on Justia Law

On appeal from the trial court's denial of a motion to compel arbitration in this wrongful death lawsuit brought against Defendant, a nursing home, the Supreme Court held that Defendant did not meet the requirements for limited statutory immunity from civil liability under either Tennessee's Durable Power of Attorney for Health Care Act, Tenn. Code Ann. 34-6-201 to -218, or the Health Care Decisions Act, Tenn. Code Ann. 68-11-1801 to -1815.After a resident of the nursing home died his estate brought the underlying wrongful death suit. Defendant moved to compel arbitration based on an arbitration agreement executed by Plaintiff on the decedent's behalf pursuant to a durable power of attorney for health care (POA) form. Plaintiff objected, arguing that the decedent did not have the mental capacity to appoint an agent when he executed the POA. The trial court concluded that the POA was invalid. The court of appeals reversed, concluding that the trial court erred in looking beyond the face of the POA to determine whether Defendant had the mental capacity to execute it. The Supreme Court reversed and affirmed the trial court, holding that the trial court did not err in considering evidence on whether the principal had the requisite mental capacity to execute the POA. View "Welch v. Oaktree Health & Rehabilitation Center LLC" on Justia Law

Michael Andary, conservator and guardian of Ellen Andary; Ronald Krueger, guardian of Philip Krueger; and Moriah, Inc., doing business as Eisenhower Center, brought an action against USAA Casualty Insurance Company and Citizens Insurance Company of America, seeking a declaratory judgment that the Michigan Legislature’s 2019 amendments of the no-fault act, MCL 500.3101 et seq., that placed new limitations on in-home family-provided attendant care in MCL 500.3157(10) and the non-Medicare fee schedule of MCL 500.3157(7) could not be applied to limit or change plaintiffs’ rights to benefits under the insurance policies defendants had issued to them before the 2019 amendments. Andary and Krueger, suffered traumatic injuries in automobile accidents before 2019, had been provided uncapped lifetime medical care covered by personal protection insurance (PIP) benefits under insurance policies and the no-fault act in effect at the time of their injuries. Plaintiffs argued that the retroactive application of the 2019 amendments to them was improper and would also violate their constitutional rights under the Contracts Clause of Const 1963, art 1, § 10 and their due-process and equal-protection rights. Additionally, plaintiffs all challenged the prospective application of the 2019 amendments on behalf of future motor vehicle accident victims and medical providers. Defendants moved to dismiss the case, and the trial court granted defendants’ motion. Plaintiffs appealed, and the Court of Appeals affirmed in part, reversed in part, and remanded the case to the circuit court. The Michigan Supreme Court found that the 2019 no-fault amendments of MCL 500.3157 did not impact services and care that were already being provided to Andary and Krueger and that had been reimbursable prior to the amendments. Andary’s and Krueger’s rights to the PIP benefits at issue in this case were both contractual and statutory in nature, and the 2019 no-fault amendments did not retroactively modify their vested contractual rights. Plaintiffs’ constitutional challenges to prospective application of the amended statutes were dismissed. View "Andary v. USAA Casualty Insurance Company" on Justia Law

A healthcare provider contended it was underpaid for substance abuse treatment that it rendered to 29 patients. Seeking to recover the difference directly from the insurance company, the provider filed suit alleging the insurer entered into binding payment agreements during verification of benefits and authorization calls with the provider and otherwise misrepresented or concealed the amounts it would pay for treatment. The trial court entered summary judgment against the provider. After review, the Court of Appeal concluded the court did not err in determining one or more elements of the provider’s causes of action could not be established. View "Aton Center v. United Healthcare Ins. Co." on Justia Law

Google and the University of Chicago Medical Center collaborated to develop software capable of anticipating patients’ future healthcare needs. The University delivered several years of anonymized patient medical records to Google, to “train” the software’s algorithms. An agreement restricted Google’s use of the records to specific research-related activities and prohibited Google from attempting to identify any patient whose records were disclosed. Dinerstein sued on behalf of himself and a class of other patients whose anonymized records were disclosed, claiming that the University had breached either an express or an implied contract traceable to a privacy notice he received and an authorization he signed upon each admission to the Medical Center. Alternatively, he asserted unjust enrichment. Citing the same notice and authorization, he alleged that the University had breached its promise of patient confidentiality, violating the Illinois Consumer Fraud and Deceptive Business Practices Act. Against Google, he claimed unjust enrichment and tortious interference with his contract with the University. He brought a privacy claim based on intrusion upon seclusion.The Seventh Circuit affirmed the dismissal of the case. To sue in federal court, a plaintiff must plausibly allege (and later prove) that he has suffered an injury in fact that is concrete and particularized, actual or imminent, and traceable to the defendant’s conduct. The injuries Dinerstein alleges lack plausibility, concreteness, or imminence (or some combination of the three). View "Dinerstein v. Google, LLC" on Justia Law

In this putative class action where Students sought a refund of money from the University of Kentucky after the University switched all on-campus classes to an online format for the remainder of the spring 2020 semester, the Supreme Court affirmed the judgment of the court of appeals affirming the trial court's ruling that governmental immunity was waived and that a breach of contract claim may proceed for adjudication on the merits, holding that the Student Financial Obligation and accompanying documents were a written contract under Ky. Rev. Stat. 45A.245(1) such that governmental immunity was waived and the underlying breach of contract claims may proceed. View "University of Ky. v. Regard" on Justia Law

The Plan is a nonprofit health care service plan subject to Health & Safety Code 1340, including the Parity Act, under which: “Every health care service plan contract . . . that provides hospital, medical, or surgical coverage shall provide coverage for the diagnosis and medically necessary treatment of severe mental illness of a person of any age, and of serious emotional disturbances of a child . . . under the same terms and conditions applied to other medical conditions.”Plaintiffs alleged that the Plan violates the Parity Act by “deterring members from obtaining one-on-one mental health therapy without making individualized determinations … encouraging ‘group’ therapy, without making individualized determinations" where similar practices are not followed in the treatment of physical health conditions. An Unruh Civil Rights Act claim alleged that the Plan intentionally discriminated against persons with mental disabilities or conditions. The court granted the Plan summary judgment.The court of appeal affirmed the rejection of one plaintiff’s individual claims; the Plan is not liable for the acts of its subsidiary by whom the plaintiff’s coverage was issued. The court otherwise reversed. On an Unfair Competition Law claim, the court failed to consider how the Plan’s conduct undermines its contractual promises of covered treatment in violation of the Parity Act. On the Unruh claim, triable issues of fact exist as to whether the plaintiffs were denied medically necessary treatment as a result of intentional discrimination. View "Futterman v. Kaiser Foundation Health Plan, Inc." on Justia Law

Alabama Somerby, LLC, d/b/a Brookdale University Park IL/AL/MC; Brookdale Senior Living, Inc.; and Undrea Wright (collectively, Brookdale) appealed a circuit court's order denying their motion to compel arbitration of the claims asserted against them by plaintiff, L.D., as the next friend of her mother, E.D. Brookdale operated an assisted-living facility for seniors ("the nursing home") in Jefferson County, Alabama; Wright was the administrator of the nursing home. In March 2022, L.D. filed on E.D.'s behalf, a complaint against Brookdale and Wright and others, asserting various tort claims and seeking related damages premised on allegations that, following her admission to the nursing home, E.D. had been subjected to multiple sexual assaults both by other residents and by an employee of Brookdale. The Brookdale defendants jointly moved to compel arbitration of L.D.'s claims against them or, alternatively, to dismiss the action without prejudice to allow those claims to proceed via arbitration. Following a hearing, the trial court, denied the motion seeking to dismiss the action or to compel arbitration. The Brookdale defendants timely appealed, asserting that the trial court had erred by failing to order arbitration. The Alabama Supreme Court concluded the Brookdale defendants established that an agreement providing for arbitration existed and that the agreement affected interstate commerce. The trial court erred in denying the Brookdale defendants' request to compel arbitration. The Supreme Court reversed the trial court's order and remanded the case for further proceedings. View "Alabama Somerby, LLC, et al. v. L.D." on Justia Law