Baptist Health v. Hutson
2011 Ark. 210
| Ark. | 2011Background
- Baptist Health appeals a circuit court order certifying a class after remand from Baptist I.
- Baptist I reversed the circuit court’s prior class-certification analysis for inadequate consideration of Rule 23 factors.
- Hutson alleges Baptist charged master-charge catalog rates for five IMS outside government or private contracts, breaching a contractual obligation to charge regular rates.
- The proposed class includes patients charged at master-charge rates for one or more IMS who paid or remain liable.
- The circuit court certified the class, finding the description definite and the common issues predominated and the class action superior.
- Baptist challenges both the class definition’s reliance on monetary liability and the predominance/superiority rulings; the court affirms.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Class definition validity | Hutson argues the definition relies on merits and is administratively feasible. | Baptist asserts the definition properly identifies class members without merits adjudication. | No abuse; class defined and ascertainable from records. |
| Predominance of common questions | Hutson contends common questions predominate over individual issues. | Baptist argues rates vary per class member, making damages individualized. | Predominance satisfied; common issue on master-charge rate governs damages framework. |
| Superiority of class action | Hutson argues class action efficiently resolves uniform issues and avoids many suits. | Baptist contends separate actions would be numerous and inconsistent. | Superiority satisfied; class action is more efficient and avoids multiple suits. |
| Standard of review and abuse of discretion | Hutson argues the circuit court properly exercised discretion on certification. | Baptist contends the court abused discretion by misapplying Rule 23 factors. | No abuse; circuit court's certification order remains within discretionary bounds. |
Key Cases Cited
- Farmers Ins. Co. v. Snowden, 366 Ark. 138 (2006) (class ascertainability may rely on objective criteria rather than every claim file detail)
- Ferguson v. Kroger Co., 343 Ark. 627 (2001) (class action prerequisites exist to determine if a class is feasible)
- Johnson’s Sales Co. v. Harris, 370 Ark. 387 (2007) (predominance begins with common wrong; bifurcated proceedings allowed)
- Campbell v. Asbury Automotive, Inc., 2011 Ark. 157 (2011) (predominance favored where common questions about rates and incentives exist)
- Gen. Motors Corp. v. Bryant, 374 Ark. 38 (2008) (court may certify for preliminary common issues and bifurcate damages)
- Teris, LLC v. Chandler, 375 Ark. 70 (2008) (certification not defeated by excluding some claims; manageability considered)
- First-Plus Home Loan Owner 1997-1 v. Bryant, 372 Ark. 466 (2008) (superiority and manageability in class actions reviewed by broad discretion)