Limberg v. Sanford Medical Center Fargo, 881 N.W.2d 658

Plaintiff Dustin Limberg, an uninsured self-pay patient, signed Sanford Medical Center’s standard admission form stating he was "financially responsible for all charges related to services provided by Sanford" and would follow Sanford’s payment guidelines.
Sanford maintains a Chargemaster listing gross charges for thousands of hospital services; insured patients often pay reduced amounts by agreement with payers, but self-pay patients are billed Chargemaster rates.
Limberg was billed based on Sanford’s Chargemaster and sued as a putative class, seeking a declaratory judgment that the contract contained an "open price" term and was ambiguous, arguing liability should be limited to the reasonable value of services.
Sanford moved to dismiss under N.D.R.Civ.P. 12(b)(6). The district court granted dismissal, finding the contract’s price term referred to the Chargemaster and was not ambiguous.
On appeal, Limberg argued the contract’s "all charges" language created an open price term and rendered the billing practices unfair, unconscionable, and unreasonable; Sanford argued the contract unambiguously incorporated its payment guidelines/Chargemaster.
The Supreme Court of North Dakota affirmed, holding the contract’s pricing term was definite, referencing Sanford’s Chargemaster, so Limberg failed to state a claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the admission contract contains an "open price" term or is sufficiently definite	Limberg: the phrase "all charges" is ambiguous/open because insured patients effectively pay less, so the contract lacks a definite price term	Sanford: the contract unambiguously ties "all charges" to Sanford’s payment guidelines/Chargemaster, which fixes the base price	Held: Contract is definite; "all charges" refers to Chargemaster rates; no open price term; dismissal affirmed
Whether equitable relief limiting recovery to "reasonable value" is available despite a written contract	Limberg: because price term is open, recovery should be limited to reasonable value; billing is unfair/unconscionable	Sanford: a clear written contract governs price; no basis to impose a reasonable-value remedy or equitable relief	Held: No equitable remedy; clear contract terms control and preclude imputing a reasonable-price term

Nygaard v. Sioux Valley Hospitals & Health System, 731 N.W.2d 184 (S.D. 2007) (hospital form referencing charges was sufficiently definite to incorporate Chargemaster rates)
DiCarlo v. St. Mary Hosp., 530 F.3d 255 (3d Cir. 2008) ("all charges" language in hospital contract unambiguous; Chargemaster governs price term)
Holland v. Trinity Health Care Corp., 791 N.W.2d 724 (Mich. Ct. App. 2010) ("usual and customary charges" unambiguously refer to Chargemaster)
Shelton v. Duke Univ. Health Sys., Inc., 633 S.E.2d 113 (N.C. Ct. App. 2006) ("regular rates" language in hospital contract refers to Chargemaster)