Summary
The North Dakota Supreme Court reviewed a summary judgment awarding A.R. Audit Services, Inc. damages for medical services provided to Charles Tuttle by Trinity Health. The court held that Tuttle failed to present sufficient evidence to create a genuine issue of material fact regarding his alleged qualification for financial assistance. The court modified the judgment to reimburse Tuttle for an $80 filing fee and affirmed it as modified.
Topics
Practice areas
Questions Presented
- Whether the district court properly granted summary judgment to A.R. Audit Services when Tuttle submitted an affidavit claiming that Trinity representatives told him he qualified for financial assistance.
- Whether the judgment should be reduced by $80 because Tuttle had paid A.R. Audit Services' filing fee.
Holdings
- Summary judgment was proper because, considering the entire evidentiary record, a reasonable person could reach only one conclusion: Tuttle remained responsible for the medical debt.
- The judgment had to be modified to reduce by $80 the amount Tuttle owed A.R. Audit because Tuttle had paid the filing fee that A.R. Audit, as plaintiff, was required to pay.
Key quotations
“A party opposing a motion for summary judgment cannot simply rely on the pleadings or on unsupported conclusory allegations.” (¶ 5)
“In light of all of the evidence submitted by A.R. Audit contradicting Tuttle’s claims, we conclude a reasonable person could reach only one conclusion from the facts, and the district court did not err in granting A.R. Audit’s motion for summary judgment.” (¶ 7)
Factual background
Trinity Health provided Charles Tuttle with $127,001.07 in medical services and later assigned the unpaid debt to A.R. Audit Services. Tuttle applied for financial assistance but did not provide all information required to process the application, and Trinity denied the application. A.R. Audit submitted Trinity's letters and a financial counselor's affidavit, while Tuttle submitted an affidavit asserting that Trinity representatives told him he qualified for assistance and owed nothing.
Procedural history
A.R. Audit Services sued Charles Tuttle to collect a medical debt assigned by Trinity Health. Tuttle asserted a counterclaim and moved to dismiss, arguing that Trinity, rather than A.R. Audit, should have sued him and that Trinity representatives had told him he qualified for financial assistance. The district court denied the motion to dismiss, dismissed the counterclaims, and granted A.R. Audit summary judgment. The North Dakota Supreme Court affirmed the judgment but modified it to reduce the amount owed by $80 for a filing-fee reimbursement.