Reiger v. St. Charles Health System, Inc., 6:24-cv-00334

Plaintiff Kristine Reiger received emergency care at St. Charles, an Oregon nonprofit hospital, after a 2022 car accident and soon incurred a medical bill.
St. Charles repeatedly attempted to collect the bill, ultimately screening Reiger for financial assistance before sending her debt to collections (Ray Klein, Inc.).
The screening showed Reiger qualified for 100% assistance (income ≤ 200% FPG), but she did not complete the application required for debt forgiveness under the hospital's policy.
After non-response, St. Charles transferred her debt to Ray Klein, who sued and obtained a default judgment (with post-judgment interest) in state court.
Reiger then filed this federal action, alleging violations of Oregon’s charity care laws, Unlawful Debt Collection Practices Act (UDCPA), Unlawful Trade Practices Act (UTPA), and the federal Fair Debt Collection Practices Act (FDCPA).
Both defendants moved to dismiss all claims; core issues included statutory interpretation and res judicata.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was St. Charles required to screen before using Ameri EBO for billing calls?	"Collection" includes any entity seeking payment, so screening was needed before Ameri EBO involvement.	Ameri EBO merely acted as St. Charles’s internal billing, not a collector for delinquent debt.	Ameri EBO not a "collector" under statute; screening not required before Ameri EBO.
If patient qualifies for 100% assistance, can unpaid charges go to collections?	Screening showing qualification for 100% aid should bar transfer to collections.	Statute only mandates procedures before transfer, does not prohibit such transfer if application incomplete.	Qualified patients can be sent to collections if application not completed.
Does interest prohibition apply if patient only "qualifies" or only if application is completed?	Interest ban applies if a patient qualifies by income, regardless of application submission.	Ban applies only after patient completes all hospital policy prerequisites.	Interest cannot be charged on debts owed by an income-qualified patient, even w/o completed application.
Are Ray Klein claims barred by res judicata?	New statutory/federal claims not litigated in the state court action, so should be heard.	All claims arise from the same transaction and could have been brought in state court.	Res judicata bars all claims against Ray Klein arising from the same debt collection matter.

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standard for 12(b)(6) motion to dismiss)
Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for claim under 12(b)(6))
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (material facts in summary judgment)
Celotex Corp. v. Catrett, 477 U.S. 317 (burdens in summary judgment)
Owens v. Kaiser Found. Health Plan, Inc., 244 F.3d 708 (elements of federal res judicata/claim preclusion)
Tahoe-Sierra Pres. Council, Inc. v. Tahoe Reg'l Plan. Agency, 322 F.3d 1064 (claims that could have been brought are barred)