Univ. Hosp. v. Campbell
2012 Ohio 1909
Ohio Ct. App.2012Background
- Campbell, uninsured at treatment, was treated at University Hospital in 2009 and billed $2,729.80.
- University filed suit in Dec. 2009 seeking payment; trial judgment awarded the full amount.
- During discovery Campbell sought contracts showing write-offs for insured patients; University refused.
- University sought summary judgment in July 2010; the trial court granted it for the full amount.
- An April 20, 2012 opinion affirmed the judgment but later was vacated and substituted due to a misstatement about a 40% discount; the substituted opinion again affirmed the trial court.
- The central issue is whether write-offs for insured patients affect the reasonable value of services to Campbell, who was uninsured.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court abused its discretion in denying production of insurer write-off contracts | Campbell argues contracts show write-offs render charges unreasonable | University contends write-offs to insured patients are irrelevant to uninsured Campbell | No abuse of discretion; write-offs were irrelevant to Campbell's case |
| Whether University’s billing practices for insured patients affect the value of services to Campbell | Campbell contends write-offs indicate unreasonableness of charges | University may grant write-offs to insured patients for volume; charges here are not shown excessive | Summary judgment proper; uninsured value is the customary charge, not insured write-offs |
| Whether the trial court correctly granted summary judgment on the amount owed based on itemized charges | Campbell failed to dispute treatment or amounts | University provided itemized statements and affidavit of amounts due | Yes; University entitled to presumptive value of charges; no competent evidence of unreasonableness by Campbell |
Key Cases Cited
- Robinson v. Bates, 112 Ohio St.3d 17 (2006-Ohio-6362) (write-offs admissible or not under collateral-source rule varies by context)
- Jaques v. Manton, 125 Ohio St.3d 342 (2010-Ohio-1838) (write-offs admissible under R.C. 2315.20; tort action context differs)
- Middleton v. Miami Valley Hosp., 2011-Ohio-5069 (2nd Dist. 2011) (presumption that hospital's charge reflects value of services)
- St. Vincent Med. Ctr. v. Sader, 100 Ohio App.3d 379 (6th Dist. 1995) (value of medical services in context of reasonable cost)
- Grace v. Mastruserio, 182 Ohio App.3d 243 (2007-Ohio-3942) (abuse-of-discretion standard for discovery rulings)
- Jorg v. Cincinnati Black United Front, 153 Ohio App.3d 258 (2003-Ohio-3668) (summary judgment de novo standard of review)