Chaffee Chiropractic Clinic, Inc. v. Stiffler
2017 Ohio 7790
| Ohio Ct. App. | 2017Background
- In Sept. 2011 Erin Stiffler (a minor) was injured in an auto accident and treated by Chaffee Chiropractic; Erin and her mother signed the clinic’s financial policy.
- A third-party insurer initially paid some bills but by March 2013 notified Chaffee Chiropractic it would make no further payments; final insurer payment covered services only through part of Nov. 2012.
- Erin resumed treatment in Jan. 2012 and continued treatment after insurer stopped payments; Chaffee created a new account in April 2013.
- Chaffee billed the family; one account showed a patient balance of $0 but an insurance balance of $8,425; Chaffee sued the Stifflers in June 2015 for unpaid charges (claims characterized as unjust enrichment/quantum meruit and account).
- Trial court granted Chaffee’s summary judgment and denied the Stifflers’ judgment-on-the-pleadings; the Stifflers appealed multiple issues which the appellate court consolidated and rejected.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did complaint/summary judgment require pleading/proving provider licensure? | Chaffee failed to plead or prove providers were licensed; contracts without licensure are void. | Legality/licensure is an affirmative defense; plaintiffs need not plead licensure. | Court: Legality is an affirmative defense; Stifflers bore burden to plead it. Summary judgment not defeated for lack of licensure proof. |
| Can Erin (minor) disaffirm and avoid liability after reaching majority? | Erin disaffirmed the contract and thus is not liable for charges. | Erin continued treatment after turning 18 and did not timely disaffirm. | Court: Disaffirmation must occur within a reasonable time after majority; here Erin did not disaffirm timely. Summary judgment stands. |
| Are Mr. and Mrs. Stiffler liable where account names only Erin? | Parents argue account lists Erin only so they cannot be liable on the account. | Parents knew of and benefited from child’s treatment; parents are generally liable for child’s medical necessaries. | Court: Even if account named Erin, unjust enrichment elements met as parents received benefit and retaining it without payment would be unjust; affirmed summary judgment on that ground. |
| Were charges necessary and reasonable? | Charges may be unnecessary or unreasonable — factual dispute exists. | Submission of detailed bill is prima facie evidence of reasonableness; no contrary admissible evidence presented. | Court: Chaffee’s itemized bill satisfied initial burden; Stifflers produced no evidence of unreasonableness or lack of necessity. Summary judgment proper. |
| Does the written financial policy limit recovery to the patient’s own insurance (not third‑party liability insurance)? | Financial policy references "your insurance" and thus cannot bind family where third‑party liability insurer was expected to pay. | Policy warned patients they are ultimately responsible and allowed delayed billing pending insurer/settlement; it does not absolve family if third‑party insurer fails to pay. | Court: Stifflers gave no legal authority; financial policy does not preclude pursuing family when third‑party insurer stops paying. Assignment overruled. |
| Was there an oral agreement that clinic accepted insurer as full payment (creating a defense)? | Mr. Stiffler avers an oral promise by Dr. Chaffee to accept insurer payment as full. | Assertion is conclusory; no evidence establishing formation or terms of an oral contract. | Court: No admissible evidence of a binding oral agreement; summary judgment affirmed. |
| Are equitable‑estoppel or estoppel‑in‑pais defenses available? | Billing delay, the clinic’s conduct, and a bill showing patient balance $0 misled family to their detriment. | Billing practices were consistent with signed financial policy; even if a billing misstatement occurred, Stifflers did not show detrimental reliance. | Court: No factual misrepresentation supporting equitable estoppel (promissory vs. equitable distinction); no actual detrimental reliance shown as bills arrived after treatment stopped. Defense fails. |
Key Cases Cited
- Grafton v. Ohio Edison Co., 77 Ohio St.3d 102 (1996) (standard for de novo review of summary-judgment rulings)
- Dresher v. Burt, 75 Ohio St.3d 280 (1996) (party moving for summary judgment bears initial evidentiary burden; nonmoving party must then produce specific Civ.R. 56 evidence)
- Temple v. Wean United, Inc., 50 Ohio St.2d 317 (1977) (elements for summary judgment under Civ.R. 56)
- Weiand v. Akron, 13 Ohio App.2d 73 (1968) (infant’s contracts are voidable; disaffirmation rule)
- Hortman v. Miamisburg, 110 Ohio St.3d 194 (2006) (distinguishing equitable estoppel and promissory estoppel; elements of equitable estoppel)