980 N.E.2d 306
Ind.2012Background
- Uninsured Plaintiffs Allen and Moore file putative class action against Clarian Health Partners for breach of contract and declaratory judgment that uninsured chargemaster rates are unreasonable.
- Allen signed a contract to pay the account for treatment; the contract contains no explicit price term, only a promise to pay if not covered by insurance.
- Clarian billed its chargemaster rates for services totaling $15,641.64; Plaintiffs contend insured discounts would have yielded $7,308.78 for the same services.
- Trial court dismissed the complaint for failure to state a claim; Court of Appeals reversed, suggesting a reasonable-price term could be implied.
- Indiana Supreme Court grants transfer and affirms the trial court, holding no reasonable-price term can be imputed and the contract refers to the chargemaster.
- Conclusion: breach claim upheld; declaratory-judgment claim not reached.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a price term is implied where the contract omits price | Allen argues price is implicit as reasonable value. | Clarian argues the price term is the chargemaster; no need to impute reasonableness. | No imputed reasonable price term; contract refers to chargemaster. |
Key Cases Cited
- DiCarlo v. St. Mary Hosp., 530 F.3d 255 (3d Cir. 2008) (charge master reference supports definite pricing)
- Banner Health v. Med. Sav. Ins. Co., 163 P.3d 1096 (Ariz. Ct. App. 2007) (charges billed per chargemaster as basis for payment)
- Nygaard v. Sioux Valley Hosp. & Health Sys., 731 N.W.2d 184 (S.D. 2007) (price term tied to hospital's chargemaster)
- Stanley v. Walker, 906 N.E.2d 852 (Ind. 2009) (collateral-source evidence not extended to contract claims)
- First Fed. Sav. Bank of Ind. v. Key Markets, Inc., 559 N.E.2d 600 (Ind. 1990) (do not engraft reasonableness into clear terms)
- Conwell v. Gray Loon Outdoor Mktg. Grp., Inc., 906 N.E.2d 805 (Ind. 2009) (certainty required; otherwise contract may be imperfectly defined)
