Medical Records Associates, Inc. v. American Empire Surplus Lines Insurance Co.

142 F.3d 512 (1998)

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Medical Records Associates, Inc. v. American Empire Surplus Lines Insurance Co.

United States Court of Appeals for the First Circuit
142 F.3d 512 (1998)

  • Written by Noah Lewis, JD

Facts

Medical Records Associates, Inc. (MRA) (plaintiff) was a medical-records processing company that contracted with Massachusetts medical facilities to carry out the facilities’ statutory obligation to furnish medical records to authorized requestors. MRA charged the requestor a statutorily authorized fee, but it could provide records without charging a fee. The law firm Lubin & Meyer sent MRA a demand letter claiming MRA overcharged for medical records in violation of state law. MRA had a professional errors and omissions (E & O) insurance policy with American Empire Surplus Lines Insurance (American Empire) (defendant), which covered losses from a negligent act, error, or omission committed in the rendering of professional services, which was defined simply as medical-records processor. MRA’s insurance application did not include billing in its description of services. American Empire refused to defend MRA. MRA settled the overcharging claim and sued American Empire for breach of contract. The district court dismissed the complaint, holding that billing practices are a ministerial act outside the scope of MRA’s professional services. MRA appealed. The appellate court granted plenary review.

Rule of Law

Issue

Holding and Reasoning (Coffin, J.)

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