Allen v. Clarian Health Partners, Inc.

980 N.E.2d 306 (2012)

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Issues

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Nature Of The Case

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Facts

Ps sought medical treatment at Clarian North Hospital, a hospital owned by D. Before receiving treatment P, who is uninsured and not covered by Medicare or Medicaid, signed a form contract drafted by Clarian under which she agreed to pay all charges associated with her treatment. The contract did not specify a dollar amount for services rendered, but provided that Allen 'guarantees payment of the account.' Clarian provided the treatment and then billed its 'chargemaster' rates for medical services and supplies in the amount of $15,641.64. Ps' class action complaint alleges breach of contract and seeks declaratory judgment, namely, that rates the hospital bills its uninsured patients are unreasonable and unenforceable. Ps claim that if insured Clarian would have accepted $7,308.78 for the same services and supplies. Ps alleges that Clarian charges only uninsured patients the chargemaster rates, while 'insured patients and Medicare/Medicaid patients pay significantly discounted rates for the same services and supplies.' D moved to dismiss the complaint for failure to state a claim upon which relief can be granted. The trial court granted the motion. Pts appealed and the Court of Appeals reversed the trial court's judgment and remanded this cause for further proceedings. The Court of Appeals concluded that because the contract did not contain a price term the reasonable value of services should be implied, and the issue of reasonableness requires resolution by a fact-finder. D appealed.

Holding & Decision

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Legal Analysis

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