Medical Recovery Services, L.L.C. v. Neumeier
Idaho Supreme Court
415 P.3d 372, 163 Idaho 504 (2018)

- Written by Mary Phelan D'Isa, JD
Facts
In late 2012, Jared Neumeier (defendant) received medical services from Dr. Eric Baird and then provided Dr. Baird’s office with his medical-insurance information, expecting that the bill would be submitted to his insurer. However, the doctor’s office did not submit the bill to Neumeier’s insurer, and instead it sought payment directly from Neumeier, sending the bill to an incorrect address. In April 2014, with no response from Neumeier, the delinquent account was assigned to Medical Recovery Services, L.L.C. (MRS) (plaintiff). That assignment gave Dr. Baird’s contractual rights with Neumeier to MRS, including interest on the claim. Neumeier never received any demand for payment related to his 2012 visit, and when he subsequently saw Dr. Baird for unrelated services, those resulted in a separate bill that was submitted to Neumeier’s insurer. In April 2015, MRS sent a letter and its complaint to Neumeier at his correct address, giving notice of the alleged debt and interest. The communication did not identify Dr. Baird or connect the debt to a particular bill or treatment. On May 14, with no response from Neumeier, MRS sent the account to its legal counsel. On May 18, after receiving the notice letter and believing it was a scam, Neumeier visited Dr. Baird’s office, and it was discovered that the 2012 bill was never submitted to Neumeier’s insurer. The same day, MRS filed its complaint against Neumeier. When Neumeier contacted MRS, he was told it was too late because the matter had been assigned to legal counsel. A month later, Neumeier was served with the complaint and summons. After Neumeier’s May 18 visit to Dr. Baird’s office, the 2012 bill was submitted to Neumeier’s insurer, which paid the bill. Neumeier was then told that his copayment was waived and that his account had been satisfied. Because the bill had been settled, the claim was reduced to zero, but MRS insisted that it was nevertheless entitled to prejudgment interest. Neumeier sought summary judgment, which the trial court granted after finding that Neumeier’s obligation to pay under his contract with Dr. Baird was subject to an implied-in-fact condition precedent that was not fulfilled. MRS appealed.
Rule of Law
Issue
Holding and Reasoning (Brody, J.)
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