Hayden v. Medcenter One, Inc.
828 N.W.2d 775
| N.D. | 2013Background
- Haydens and law firm sue medical providers in state court for reimbursement of expenses and attorney fees incurred pursuing insurer to cover Todd Hayden’s June 2009 injuries.
- Todd Hayden was insured under Blue Cross Blue Shield of Texas; Billings Clinic and Medcenter One billed over $1 million for care after a ATV accident.
- BCBSTX initially paid some claims but stopped, prompting federal suit in North Dakota to compel coverage; in 2011 BCBSTX began paying at discounted rates to providers.
- January 2012 action sought reimbursement from providers under theories of unjust enrichment, quantum meruit, equitable estoppel, and the common fund doctrine; district court granted summary judgment for providers.
- Court held Hayden claims fail as a matter of law; Hayden status as co-conservators/guardians acknowledged but no personal obligation to pay the bills; appeal focuses on equitable/fee theories and common fund doctrine.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Unjust enrichment viability | Haydens contend providers were unjustly enriched by insurance payments | District court correctly found no unjust enrichment | No; dismissal upheld |
| Quantum meruit viability | Haydens seek fees due to benefits conferred by pursuing insurer action | No implied contract or notice of payment expectation | No; dismissal upheld |
| Equitable estoppel viability | Haydens rely on attorney communications suggesting a lost cause | No affirmative deceptive conduct by providers; estoppel not applicable | No; dismissal upheld |
| Common fund doctrine applicability | Law firm seeks fees from common fund created by insurer action | Common fund doctrine not applicable to hospital liens and third-party beneficiaries | No; doctrine does not apply |
Key Cases Cited
- Wilson v. Sisters of St. Francis Health Servs., Inc., 952 N.E.2d 793 (Ind.Ct.App.2011) (unjust enrichment/fees not recoverable when hospital is a stranger to contract)
- Lynch v. Deaconess Med. Ctr., 776 P.2d 681 (Wash. 1989) (attorney fees not recoverable where hospital is entitled to full payment; incidental benefit not enough)
- Zuger v. North Dakota Ins. Guar. Ass’n, 494 N.W.2d 135 (N.D.1992) (non-contracting parties not obligated to pay for services; no unjust enrichment)
- Wendling v. Illinois Hosp. Servs., 950 N.E.2d 646 (Ill. 2011) (majority rule: hospitals not required to pay share of fees from fund creation; incidental benefit only)
- Bishop v. Burgard, 764 N.E.2d 24 (Ill.2002) (ERISA subrogation lien vs common fund; distinction for subrogation beneficiaries)