Shahin v. Memorial Hermann Health System, 527 S.W.3d 484

Shahin, an uninsured patient, received emergency care at Memorial Hermann; her hospital bill (Chargemaster list price) totaled about $5,551.75 after a $300 payment.
Shahin did not apply for the hospital’s financial assistance, although her admission paperwork obligated her to do so if eligible.
She sued for declaratory relief seeking a declaration that the hospital may only charge the "reasonable value" of services (not Chargemaster list prices) and sought class certification for similarly billed uninsured patients.
Memorial Hermann filed a plea to the jurisdiction arguing the claim was unripe because the bill could be reduced or written off through financial-assistance procedures and that Shahin’s requested declaration would not resolve a concrete controversy about the reasonableness of her specific charges.
The trial court dismissed Shahin’s declaratory-judgment claim without stating grounds; the court of appeals reviewed whether the record supported dismissal for lack of subject-matter jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ripeness of declaratory claim over billed amount	Shahin: bill is final enough — demand, balance due, due date, and collection threat make the controversy ripe	Memorial Hermann: ultimate obligation depends on application for financial assistance and possible discounts or write-off, so injury is speculative	Court: Not ripe — record showed billing was contingent and no final determination on adjustments; dismissal proper
Whether declaratory relief is appropriate to decide permissible hospital rates	Shahin: declaration that hospital may only charge reasonable value would aid resolution	Memorial Hermann: decree would be useless because Shahin did not ask the court to find the Chargemaster rates unreasonable; issue is factual	Court: Declaratory judgment is improper because the dispute primarily raises factual questions (reasonableness/necessity) rather than pure legal construction

Tex. Dep’t of Transp. v. Jones, 8 S.W.3d 636 (Tex. 1999) (subject-matter jurisdiction limits and plea to the jurisdiction principles)
Tex. Dep’t of Parks & Wildlife v. Miranda, 133 S.W.3d 217 (Tex. 2004) (standard for pleading jurisdictional facts; accept plaintiff’s allegations and construe in their favor)
Waco Indep. Sch. Dist. v. Gibson, 22 S.W.3d 849 (Tex. 2000) (ripeness requires concrete, not speculative, injury)
Haygood v. De Escobedo, 356 S.W.3d 390 (Tex. 2011) (difficulty of determining reasonable medical expense and limits on using billed list prices)
Metro. Transit Auth. v. McChristian, 449 S.W.3d 846 (Tex. App.—Houston [14th Dist.] 2014) (an uninsured, unadjusted medical statement can sometimes be sufficiently definite to prove incurred expenses)
Big Bird Tree Servs. v. Gallegos, 365 S.W.3d 173 (Tex. App.—Dallas 2012) (written-off medical charges may be evidence of incurred expenses where charity would seek recovery)
Drexel Corp. v. Edgewood Dev., Ltd., 417 S.W.3d 672 (Tex. App.—Houston [14th Dist.] 2013) (letter demanding payment can create a ripe controversy for declaratory relief)
Huston v. United Parcel Serv., Inc., 434 S.W.3d 630 (Tex. App.—Houston [1st Dist.] 2014) (interpreting Haygood and exclusion of billed-but-unrecoverable differences when calculating recoverable amounts)