Charlotte-Mecklenburg Hospital Authority v. Talford, 366 N.C. 43

Plaintiff hospital sought $14,419.57 for medical services provided to defendant during Nov 5–8, 2007.
Defendant admitted receipt of services but disputed the reasonableness/amount of the charge.
Plaintiff moved for summary judgment supported by affidavits from its staff stating the amount and that it was reasonable.
Defendant denied and submitted his own affidavit comparing hospital charges to retail prices for certain medications.
The trial court granted summary judgment for plaintiff; Court of Appeals reversed on damages, but on review the Supreme Court considered the reasonableness forecast.
The court held plaintiff’s affidavits were minimally sufficient to forecast reasonable value; defendant’s affidavit failed to raise a genuine issue about reasonableness.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiff forecast sufficient evidence of reasonable value	Talford forecast sufficient evidence via affidavits and complaint showing market-based reasonableness.	Defendant argued the affidavits were insufficient to prove reasonableness; price differences show unreasonableness.	Yes; plaintiff forecast sufficient evidence of reasonable value
Whether defendant's price-difference affidavit creates a material issue	Affidavits show market norms and regulations; sufficient for summary judgment.	Differences between retail and charged prices demonstrate unreasonableness.	No; defendant failed to raise a genuine issue of material fact
Whether the trial court properly granted summary judgment on damages	Affirmative; evidence supports reasonable value under quantum meruit/express contract theories.	No; evidence undermines reasonableness and credibility of plaintiff’s affiants.	Yes; summary judgment for plaintiff affirmed on liability/damages foreseen, subject to reversal on damages by Court of Appeals is reversed

Kidd v. Early, 289 N.C. 343 (1976) (summary judgment on movant's own affidavits requires credibility considerations)
Turner v. Marsh Furn. Co., 217 N.C. 695 (1940) (market value considers time, labor, skill, and attendant circumstances)
Cline v. Cline, 258 N.C. 295 (1962) (guides market value factors for services)
Hood v. Faulkner, 47 N.C. App. 611 (1980) (ledger-like price evidence alone insufficient for market value)
Paxton v. O.P.F., Inc., 64 N.C. App. 130 (1983) (market value requires more than unilateral pricing estimates)
Sherman Hosp. v. Wingren, 169 Ill. App. 3d 161 (1988) (hospital charges must be reasonable and comparable to area charges)