Unilab Corp. v. Angeles-IPA CA2/4
244 Cal. App. 4th 622
| Cal. Ct. App. | 2016Background
- Quest seeks payment from Angeles-IPA for post-contract laboratory tests ordered for Angeles patients.
- Angeles terminated Quest's fee-for-service contract in 2009 and directed physicians to use AMA Laboratory for in-network testing.
- Misrouting occurred when Quest drop boxes, used by physicians in Quest-affiliated IPAs, contained Angeles patient specimens without proper IPA/payor identification.
- Quest argued theories of implied-in-fact contract, unjust enrichment (quasi-contract), and implied-in-law obligations under the Knox-Keene Act.
- The trial court granted summary adjudication on most causes; Quest dismissed remaining claims; judgment for Angeles;
- On appeal, the court affirmed, finding no triable issue supporting recovery for post-contract tests.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did an implied-in-fact contract exist to pay for post-contract tests? | Quest argues Angeles' participation through physicians created agency and implied payment obligation. | Angeles did not create agency or obligation; contract with physicians and independent contractor status negate implied payment. | No triable issue; no implied-in-fact contract. |
| Can Quest claim recovery under a quasi-contract/unjust enrichment theory? | Angeles benefitted from Quest's services and should reimburse to avoid unjust enrichment. | Beneficiaries of physicians' duties to intermediaries; no unjust enrichment by Angeles; no contract. | Quasi-contract/restitution claims fail. |
| Does Knox-Keene Act imply a private obligation on Angeles to pay for post-contract tests? | Knox-Keene framework shifts risk to Angels; pays implied by public policy. | Statutes do not create private payment duties between IPA and Quest; no private right of action. | No implied-in-law obligation established. |
| Was there an agency relationship between Angeles and its in-network physicians for payment of misdirected tests? | Physician referrals inside Quest drop boxes created agency to pay on Angeles' behalf. | Contracts define independent contractor status; no control or authority over physicians for post-contract payments. | No agency relationship found; no payment obligation. |
Key Cases Cited
- California Medical Assn. v. Aetna U.S. Healthcare of California, Inc., 94 Cal.App.4th 151 (Cal. Ct. App. 2001) (quasi-contract claims fail where benefits arise from intermediary agreements)
- Bell v. Blue Cross of California, 131 Cal.App.4th 211 (Cal. Ct. App. 2005) (statutory reimbursement issues; private right to sue denied for non-emergency providers)
- Heritage Provider Network, Inc. v. Superior Court, 158 Cal.App.4th 1146 (Cal. Ct. App. 2008) (independent contractor status in IPA networks; agency implications clarified)
- Major-Blakeney Corp. v. Jenkins, 121 Cal.App.2d 325 (Cal. Ct. App. 1953) (illustrates incidental benefit not giving rise to restitution absent unjust enrichment)
- Eamoe v. Big Bear Land & Water Co., 98 Cal.App.2d 370 (Cal. Ct. App. 1950) (agency authority and liability for unauthorized acts of agent)
- Gorlach v. Sports Club Co., 209 Cal.App.4th 1497 (Cal. Ct. App. 2012) (summary judgment standard in implied contract analysis)