Melmark, Inc. v. Schutt Ex Rel. Schutt
169 A.3d 638
| Pa. Super. Ct. | 2017Background
- Melmark, a Pennsylvania residential care provider, cared for Alexander (Alex), a 31‑year‑old New Jersey resident with severe autism; unpaid services from April 1, 2012 to May 14, 2013 totaled $205,236.38.
- Alex had long received New Jersey public benefits (NJDDD, Medicaid, SSDI) and his parents, Clarence and Barbara Schutt (both over 70), are New Jersey domiciliaries and his legal guardians.
- NJDDD stopped payment after a rate/dispute with Melmark and offered alternative placement; the Schutts resisted transfer and pursued, then cancelled, administrative relief, leaving Melmark unpaid while continuing care.
- Melmark sued in Delaware County, PA, seeking recovery from Alex (through his guardians) and from the Schutts individually under unjust enrichment, quantum meruit, and Pennsylvania filial support statute (23 Pa.C.S. § 4603).
- The trial court awarded judgment against Alex (in his fiduciary capacity/estate) for the unpaid services but held the Schutts individually not liable, applying New Jersey filial support law which exempts persons 55 or older from support liability for adult children.
- On appeal, Melmark challenged the choice‑of‑law decision, the court’s authority under §4603 to set the amount, and denial of recovery under unjust enrichment/quantum meruit.
Issues
| Issue | Plaintiff's Argument (Melmark) | Defendant's Argument (Schutts) | Held |
|---|---|---|---|
| Which state’s filial support law applies (PA or NJ)? | Pennsylvania law should apply because services were provided in PA and PA has interest in enabling local providers to collect from family members. | New Jersey law should apply because Alex and his parents are domiciled in NJ and NJ has an interest in shielding elderly parents under its family support scheme. | Court applied NJ law; NJ has the more significant contacts and interest, so Schutts not personally liable. |
| Does 23 Pa.C.S. §4603(b)(1) allow PA court to set amount when indigent person domiciled out‑of‑state? | PA statute authorizes recovery and amount should be set by PA court regardless of Alex’s NJ domicile. | PA statute requires the amount be set in the judicial district where the indigent person resides; Alex resided in NJ so PA court lacks authority. | Trial court found §4603(b)(1) divests court of authority because Alex was a NJ resident; PA court did not set amount under PA filial statute. |
| Was there a conflict of law between NJ and PA filial statutes? | No true conflict because NJ statute primarily applies to public assistance recipients under 18 and NJ had no interest when no NJ payments were being made. | Yes: NJ statute contains an explicit age‑based exemption protecting elderly parents of adult public‑assistance‑eligible children. | Court found a real conflict and that NJ’s protective purpose applied given Alex’s long history of NJ public assistance; NJ law governs. |
| Were the Schutts liable under unjust enrichment / quantum meruit? | Even absent filial support liability, quantum meruit/unjust enrichment should permit recovery from parents who accepted/retained benefit by permitting son’s stay. | No unjust enrichment because parents had no legal obligation, did not personally receive benefit, and did not contract with Melmark. | Court held no recovery against the Schutts individually; unjust enrichment/quantum meruit failed because benefit was conferred on Alex, not the parents, and they had no legal duty to pay under NJ law. |
Key Cases Cited
- Wilson v. Transport Ins. Co., 889 A.2d 563 (Pa. Super. 2005) (choice‑of‑law analysis requires determining whether a conflict exists between competing states’ laws)
- Griffith v. United Air Lines, Inc., 203 A.2d 796 (Pa. 1964) (forum court applies forum state choice‑of‑law rules)
- Budtel Associates, LP v. Continental Cas. Co., 915 A.2d 640 (Pa. Super. 2006) (first step: determine whether a true conflict exists; then evaluate states’ interests)
- Troxel v. A.I. DuPont Inst., 636 A.2d 1179 (Pa. Super. 1994) (evaluate which state has the priority of interest and significant contacts)
- Eades v. Kennedy, PC Law Offices, 799 F.3d 161 (2d Cir. 2015) (distinguishable federal decision finding no protective purpose in federal nursing‑home statutory scheme)
- Durst v. Milroy, 52 A.3d 357 (Pa. Super. 2012) (elements and nature of quantum meruit/unjust enrichment)
- Schneck v. K.E. David, Ltd., 666 A.2d 327 (Pa. Super. 1995) (application of unjust enrichment/quantum meruit depends on factual circumstances)