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Christus Health v. Quality Infusion Care Inc.

A jury trial culminated in findings that Christus Health Services failed to comply with the medical plan by denying Quality Infusion Services payment, but that the failure to comply was excused. The jury also awarded Quality quantum meruit recovery. An express contract between the parties precludes a plaintiff from recovering for services rendered in quantum meruit if the contract covers those services or materials and if no exception to the general rule applies. The trial court's judgment is reversed and rendered. Houston's 1st Court of Appeals, No. 01-09-00591-CV, 12-08-2011.

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OPINION ON REHEARING

Christus Health Services, d/b/a Uniform Services Family Health Plan (Christus) manages a network of medical and healthcare providers in east Texas and western Louisiana. The health plan is for active and retired members of the Armed Services, their families, and survivors. Quality Infusion Services (Quality) provided medical services to several Christus members referred to it by a specialist in Christus’s network. Quality itself, however, was not part of the network. Christus paid some of Quality’s invoices, but denied others on the basis that Quality had not complied with the terms of the medical plan. Quality sued Christus to collect the unpaid invoices, claiming that Christus breached its duty to pay or, alternatively, owed it an equitable recovery on a quantum meruit theory.

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