Allen v. Clarian Health Partners, Inc. (Summary)

BREACH OF CONTRACT: HOSPITAL CHARGES

Allen v. Clarian Health Partners, Inc., No. 49S02-1203-CT-140 (Ind. Dec. 19, 2012)

The Supreme Court of Indiana affirmed a trial court’s dismissal of uninsured patients’ challenges to the reasonableness of a hospital’s charges.  The patients had signed forms stating that they agreed to pay all charges associated with treatment.  After receiving treatment and their bills, the patients sued the hospital’s parent corporation, alleging that the hospital’s rates were unreasonable, and therefore unenforceable.

The hospital filed a motion to dismiss the case. The trial court granted the hospital’s motion to dismiss. The Indiana Court of Appeals reversed, ruling that because the contract did not include a price term, the reasonable value of services should be implied and the issue of reasonableness requires resolution by a fact-finder.

The Supreme Court of Indiana affirmed the trial court’s dismissal of the case. In Indiana, if a price term in a contract is indefinite, courts impute a reasonable price. However, here, the court found that the price was not indefinite, because the rates were fixed by the hospital’s chargemaster.