Limberg v. Sanford Medical Center Fargo

Summary

The North Dakota Supreme Court affirmed dismissal of a putative class action challenging Sanford Medical Center Fargo's billing of uninsured patients at Chargemaster rates. The court held that the patient's agreement to pay all charges under Sanford's payment guidelines provided a sufficiently definite price term and did not constitute an open-price contract. The court also rejected claims that the patient was entitled to be charged only the reasonable value of the services.

Holdings

1. The contract's requirement that patients pay all charges related to Sanford's services according to Sanford's payment guidelines was reasonably definite and certain and referred to the rates in Sanford's Chargemaster. The contract therefore did not contain an open price term or an ambiguous price term.
2. Because the written contract contained a definite and unambiguous price term, Limberg was not entitled to have a reasonable price implied or to proceed on an equitable reasonable-value theory.
3. The complaint failed to state a legally sufficient claim because Limberg could not prove that Sanford's contract contained an open price term or that a reasonable price should be substituted for the contractually determined charges.

Questions Presented

1. Whether Sanford's patient financial-responsibility contract contained an open or ambiguous price term because it required payment of all charges according to Sanford's payment guidelines.
2. Whether Limberg could obtain a reasonable-value or equitable remedy on the theory that Sanford's billing practices were unfair, unconscionable, or unreasonable despite the written contract.
3. Whether the complaint stated a claim upon which relief could be granted under N.D.R.Civ.P. 12(b)(6).

Disposition

affirmed