Potvin v. Metropolitan Life Insurance Company
California Supreme Court
997 P.2d 1153 (Cal. 2000)
Metropolitan Life Insurance (MetLife) (defendant) entered into a contract with Dr. Louis Potvin (plaintiff) to include him as a participant on two of its preferred provider lists. Under the non-exclusive contract, Potvin provided services to individuals covered by MetLife in return for a set fee. Termination of the agreement could be had by either party providing 30-days written notice. MetLife notified Potvin in writing that it was terminating his status as a preferred provider, without cause. Potvin asked for clarification. MetLife notified Potvin that he did not meet the retention standard due to his malpractice history. Potvin had been sued four times for malpractice, prior to his contract with MetLife. Three of the suits were dismissed and one settled. After unsuccessfully attempting to get a hearing on the matter, Potvin filed suit against MetLife alleging that the termination devastated his practice and reputation. The trial court granted MetLife’s motion for summary judgment on grounds that Potvin’s complaint failed to allege a claim. Potvin appealed and the court of appeals reversed, holding that his complaint did properly allege a claim and that MetLife should have provided Potvin with an opportunity for a hearing on the termination. Metlife appealed to the state supreme court.
Rule of Law
Holding and Reasoning (Kennard, J.)
Dissent (Brown, J.)
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