Allen v. Clarian Health Partners, Inc.
Indiana Supreme Court
980 N.E.2d 306 (2012)
Abby Allen (plaintiff) was uninsured and needed medical treatment. Allen went to Clarian North Hospital, which was owned by Clarian Health Partners, Inc. (Clarian) (defendant). Allen signed Clarian’s standard contract agreeing to pay for the costs of her treatment out of her own pocket. The contract did not contain any terms explaining how the treatment costs would be determined. After Clarian treated Allen, it billed her according to its chargemaster rates, a chargemaster being a hospital’s unique, comprehensive price list for its goods and services. Although insurance companies and Medicare/Medicaid programs often negotiated lower rates than a hospital’s baseline chargemaster rates, Clarian used the full chargemaster rates to bill Allen approximately $15,600 for her treatment. Allen sued, claiming that Clarian would have charged most insurance companies only around $7,300 for her treatment. Because the contract did not include a price term, Allen contended that the implied contractual term was a reasonable price and that a reasonable price was the amount an insurance company would have been charged. Allen believed it was unreasonable to charge uninsured people more than twice that amount. The district court dismissed the case, finding that Allen had not stated a valid legal claim. The court of appeals reversed the dismissal, finding that the contract did imply a reasonable price term and that the case should go to a jury or other fact-finder to decide what was reasonable in this situation. Clarian appealed to the Indiana Supreme Court.
Rule of Law
Holding and Reasoning (Rucker, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 725,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 725,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 45,700 briefs, keyed to 983 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.