Chino Valley Pathology Med. Group v. Doctors' Hosp. Med. Ctr. of Montclair, B190108 c/w B191450 ( Cal. Ct. App. Jan. 29, 2008)

In this contract dispute between a hospital and a pathology medical group ("group"), the California Court of Appeal reversed the lower court's summary judgment in favor of the hospital and held that the contract was ambiguous and since extrinsic evidence offered by the parties to aid interpretation was contradictory, a question of fact existed, which precluded summary judgment.

The group initially filed suit against the hospital to recover for the professional component of payments to the hospital for anatomical and clinical pathology services which the group provided to Medi-Cal beneficiaries. The hospital alleged that the plain language of the contract did not entitle the group to such payments. The appellate court disagreed and found that a reading of the plain words of the contract resulted in an ambiguity as to which clinical pathology services were to be attributed to the group and which to the hospital, for payment and all other purposes. Since extrinsic evidence offered by the parties to aid in resolving this ambiguity was contradictory, the court concluded that a question of fact existed that precluded summary judgment.