Christus Health D/B/A Uniform Services Family Health Plan v. Quality Infusion Care, Inc

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.

A jury trial culminated in findings that Christus failed to comply with the medical plan by denying Quality payment, but that the failure to comply was excused. The jury also awarded Quality quantum meruit recovery in the amount of $225,000. The trial court entered judgment on the jury’s quantum meruit findings. Christus appeals, seeking reversal on the grounds that: (1) the existence of an express contract covering the medical treatments at issue precludes quantum meruit recovery; (2) the evidence does not support findings that Christus “accepted,” “used,” or “enjoyed” the services and pharmaceutical drugs provided by Quality required for quantum meruit recovery; and (3) federal law preempts Quality’s quantum meruit claim. We hold that the express contract rule bars Quality from a quantum meruit recovery and reverse.