Sign In
Events
Newsletters
Search

Close

Close Search

Cancel

SEARCH
MY LAW.COMNEW

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

X

Thank you for sharing!

Your article was successfully shared with the contacts you provided.
OPINION

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.

Trending Stories

 
Reprints & Licensing
Mentioned in a Law.com story?

License our industry-leading legal content to extend your thought leadership and build your brand.

LEARN MORE

More From ALM

Premium Subscription
With this subscription you will receive unlimited access to high quality, online, on-demand premium content from well-respected faculty in the legal industry. This is perfect for attorneys licensed in multiple jurisdictions or for attorneys that have fulfilled their CLE requirement but need to access resourceful information for their practice areas.
View Now
Team Accounts
Our Team Account subscription service is for legal teams of four or more attorneys. Each attorney is granted unlimited access to high quality, on-demand premium content from well-respected faculty in the legal industry along with administrative access to easily manage CLE for the entire team.
View Now
Bundle Subscriptions
Gain access to some of the most knowledgeable and experienced attorneys with our 2 bundle options! Our Compliance bundles are curated by CLE Counselors and include current legal topics and challenges within the industry. Our second option allows you to build your bundle and strategically select the content that pertains to your needs. Both options are priced the same.
View Now
Go to CLE Center
General Counsel Conference Southwest 2024
September 18, 2024 - September 19, 2024
Dallas, TX

Join General Counsel and Senior Legal Leaders at the Premier Forum Designed For and by General Counsel from Fortune 1000 Companies


Learn More
Women, Influence & Power in Law US Awards 2024
September 24, 2024
Chicago, IL

Women, Influence & Power in Law Awards honors women lawyers who have made a remarkable difference in the legal profession.


Learn More
Women, Influence & Power in Law (WIPL) 2024
September 23, 2024 - September 25, 2024
Chicago, IL

WIPL is the original global forum facilitating women-to-women exchange on leadership and legal issues.


Learn More
Go to Events Go to Webcasts
Litigation Associate Miami, FL

Description: Fox Rothschild LLP has an opening in the Miami office for an associate in the Litigation Department. The ideal candidate will h...


Apply Now ›
Dean

Search for the Dean University of the Pacific, McGeorge School of Law The University of the Pacific seeks an exceptional leader to serve as...


Apply Now ›
Dean of the College of Law

Dean of the College of Law Founded in 1898 by the Congregation of the Mission, DePaul University is the nation s largest Catholic institutio...


Apply Now ›
Go to Lawjobs