OSF Saint Francis Medical Center v. Star Transport Inc. Health Care Plan
1:15-cv-01460
C.D. Ill.Jul 5, 2017Background
- Plaintiff OSF Healthcare sued Star Transport, Inc. Health Care Plan under ERISA for reimbursement after providing medical services to an insured who assigned benefits to OSF.
- Original claim sought $97,063.90; OSF alleged $59,778.43 remained unpaid.
- Summons was served April 13, 2016; Star failed to answer by the deadline.
- Case was briefly stayed due to Star’s bankruptcy filing, then the stay was lifted; default was entered November 22, 2016.
- OSF moved for default judgment seeking $59,778.43 in unpaid bills, $4,050 in attorney’s fees, and $422.50 in costs, supported by affidavits.
- The court found Star in default, treated well-pleaded allegations as true, and granted OSF’s motion for default judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Valid service and failure to respond | Service was effected April 13, 2016; Star did not answer by required date | No responsive pleading or defense was filed | Court found service effective and Star in default |
| Liability for unpaid ERISA benefits | OSF asserted entitlement to reimbursement for assigned benefits totaling $59,778.43 | No defense raised (default) | Court accepted complaint allegations as true and awarded $59,778.43 |
| Entitlement to attorney’s fees under ERISA §1132(g)(1) | OSF sought $4,050 in fees, supported by affidavit | No opposition (default) | Court awarded $4,050 in attorney’s fees |
| Recovery of court costs | OSF sought $422.50 in costs, supported by affidavit | No opposition (default) | Court awarded $422.50 in costs |
Key Cases Cited
- e360 Insight v. The Spamhaus Project, 500 F.3d 594 (7th Cir. 2007) (default judgment requires personal jurisdiction)
- Dundee Cement Co. v. Howard Pipe & Concrete Prod., Inc., 722 F.2d 1319 (7th Cir. 1983) (well-pleaded allegations in complaint are taken as true upon default)
- Breuer Elec. Mfg. Co. v. Toronado Sys. of Am., Inc., 687 F.2d 182 (7th Cir. 1982) (default judgment establishes defendant’s liability as a matter of law)