Ricky Hendrix, Individually and on Behalf of All Arkansans Similarly Situated v. Municipal Health Benefit Fund

Summary

The Arkansas Supreme Court affirmed summary judgment for the Municipal Health Benefit Fund in a class action challenging the Fund’s use of a usual, customary, and reasonable charges exclusion. The court held that the Fund’s Policy Booklet was an extension of the trust rather than a separate contract, and that the plaintiff’s claim was improperly pleaded as breach of contract instead of breach of trust or fiduciary duty. The court therefore affirmed on the basis that the circuit court reached the correct result for the wrong reasons.

Holdings

1. A cross-appeal was not required because the Fund sought no affirmative relief beyond affirmance of the judgment; it could argue that the circuit court reached the correct result for a different reason.
2. The Policy Booklet was not a separate contract between the Fund and Hendrix or the class members; it was an extension of the trust and contained rules and regulations adopted by the trustees under the Declaration of Trust.
3. Hendrix failed to state a proper breach-of-contract claim because the alleged misconduct concerned the trustees' administration of the trust and Hendrix did not assert a breach-of-trust or breach-of-fiduciary-duty claim.

Questions Presented

1. Whether the Fund was entitled to summary judgment on Hendrix's claim challenging the UCR exclusion.
2. Whether the Policy Booklet created a separate contract between the Fund and its beneficiaries, or instead constituted rules and regulations governing administration of the Fund trust.
3. Whether the Fund could defend the judgment on the ground that Hendrix's claim was actually a challenge to trustee conduct despite not filing a cross-appeal.
4. Whether Hendrix was entitled to summary judgment and a remand for a damages determination.

Disposition

affirmed