State of Iowa, Department of Human Services ex rel. Palmer v. Unisys Corp.
Iowa Supreme Court
637 N.W.2d 142 (2001)
- Written by Eric Miller, JD
Facts
The State of Iowa, through its Department of Human Services (the state) (plaintiff) contracted with various health-maintenance organizations (HMOs) to provide services to Medicaid recipients. The state paid the HMOs capitation rates—that is, monthly fees paid regardless of the extent of services provided. The state hired Unisys Corporation (defendant) as the program’s fiscal agent responsible for calculating capitation rates. However, Unisys miscalculated the rates for 1994 and 1995, resulting in significant overpayments to the HMOs. The state brought a claim to recover these amounts from Unisys, which in turn filed a cross-petition against Heritage, the HMO that received the bulk of the overpayments. The cross-petition was based on theories of indemnity, contribution, and unjust enrichment. The district court granted summary judgment in favor of Heritage, finding that Unisys lacked standing to assert a claim. Unisys appealed to the Iowa Supreme Court on the contribution and unjust-enrichment claims.
Rule of Law
Issue
Holding and Reasoning (Cady, J.)
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