The Catholic Diocese of Gary and St. Joseph Catholic School v. Douglas N. Crawley and Patricia Crawley (mem. dec.)
45D04-1610-PL-2342
| Ind. Ct. App. | May 31, 2017Background
- Douglas Crawley worked at St. Joseph Catholic School (Diocese of Gary) beginning August 2005; he became full-time and eligible for diocesan health insurance but was not informed of eligibility.
- In October 2006 Douglas was hospitalized and his medical bills were submitted to his wife’s employer plan (St. Catherine Hospital), which required spouses to use their own employer coverage if available.
- In April 2007 a St. Catherine HR rep (Pat Mason) contacted the Diocese; the hospital then determined Douglas was eligible under the Diocese plan and denied the hospital’s payment of his claims.
- The Diocese later presented Douglas with a back‑dated “Voluntary Waiver of Health Insurance Benefits” form (which Douglas did not sign).
- A collection action was filed against the Crawleys; they filed a third‑party complaint against the Diocese alleging breach of contract, actual fraud, constructive fraud, and ERISA violations. The trial court granted summary judgment for the Diocese on ERISA (church‑plan exclusion) but denied summary judgment on the other claims; the Diocese appealed interlocutorily.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Existence of contract | Crawleys: Diocese had contractual obligation to inform Douglas of eligibility based on benefit materials/policy | Diocese: No offer/acceptance/consideration; Anthem booklet is informational, not a contract; Crawleys produced no contractual document | No genuine issue — Crawleys failed to present evidence of a contract; summary judgment for Diocese on breach claim |
| Fraud from failure to inform | Crawleys: Diocese’s nondisclosure of eligibility was fraudulent (duty to disclose) | Diocese: Allegation is a repackaged contract claim; fraud must be separate and cause distinct injury | Held as repackaged breach; no distinct injury shown; summary judgment for Diocese on fraud claim |
| Fraud from back‑dated waiver form | Crawleys: Diocese attempted to procure a back‑dated waiver, showing fraudulent conduct | Diocese: Form was presented after hospitalization and was unsigned; reliance and causation lacking | No detrimental reliance or causation (events postdate injury); summary judgment for Diocese |
| Fraud from statements to hospital (Pat Mason) | Crawleys: Diocese told Mason Douglas either was not eligible or had declined coverage, causing denial | Diocese: Mason’s contact occurred April 2007—after treatment and billing began—so no reliance or causation | Statements occurred after bills accrued; no proximate reliance; summary judgment for Diocese |
Key Cases Cited
- Hughley v. State, 15 N.E.3d 1000 (Ind. 2014) (standard of review for summary judgment)
- Doe v. Adams, 53 N.E.3d 483 (Ind. Ct. App. 2016) (moving party’s burden on summary judgment)
- Ind. Dep’t of State Revenue v. Belterra Resort Ind., LLC, 935 N.E.2d 174 (Ind. 2010) (elements required for contract formation)
- Kesling v. Hubler Nissan, Inc., 997 N.E.2d 327 (Ind. 2013) (elements of actual/common‑law fraud)
- Sheaff Brock Inv. Advisors, LLC v. Morton, 7 N.E.3d 278 (Ind. Ct. App. 2014) (elements of constructive fraud and rule on when fraud is distinct from contract)
- Tobin v. Ruman, 819 N.E.2d 78 (Ind. Ct. App. 2004) (fraud claims based solely on contractual representations are treated as breach of contract)