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980 N.E.2d 306
Ind.
2012
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Background

  • 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)
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Case Details

Case Name: Abby Allen and Walter Moore v. Clarian Health Partners, Inc.
Court Name: Indiana Supreme Court
Date Published: Dec 19, 2012
Citations: 980 N.E.2d 306; 2012 WL 6608042; 2012 Ind. LEXIS 991; 49S02-1203-CT-140
Docket Number: 49S02-1203-CT-140
Court Abbreviation: Ind.
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    Abby Allen and Walter Moore v. Clarian Health Partners, Inc., 980 N.E.2d 306