Sunrise Healthcare Corp. v. Azarigian

821 A.2d 835 (2003)

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Sunrise Healthcare Corp. v. Azarigian

Connecticut Appellate Court
821 A.2d 835 (2003)

Facts

Gloria Wood had a power of attorney that made her daughter, Vicki Azarigian (defendant), Wood’s legal representative and gave Azarigian control of Wood’s assets. In order to have Wood admitted into a nursing home operated by Sunrise Healthcare Corporation (nursing home) (plaintiff), Azarigian signed a contract with the nursing home agreeing to (1) ensure that Woods was eligible for Medicaid and (2) use Wood’s assets to pay for Wood’s welfare, such as by paying for nursing-home care. After Wood was admitted, Azarigian used Wood’s assets to pay the nursing-home bills, continue Wood’s preadmission pattern of making certain gifts, and pay for a personal companion to assist Wood at the nursing home. After a year, Azarigian stopped paying the nursing-home bills. Azarigian applied for Medicaid to cover Wood’s nursing-home care. However, the application was denied because Azarigian had given away assets that Wood could have used to pay for her care. Wood died with approximately $79,000 of unpaid nursing-home bills. The nursing home sued Azarigian, alleging that she had breached the terms of the admission contract and, therefore, was responsible for the unpaid $79,000 as contractual damages. The trial court entered judgment for the nursing home. Azarigian appealed, arguing that the nursing-home contract violated the Medicaid laws because it made a resident’s legal representative personally guarantee the resident’s nursing-home costs. Azarigian also argued that she had not breached the contract because the gifts and personal-companion payments were made for Wood’s welfare, as allowed by the contract.

Rule of Law

Issue

Holding and Reasoning (Peters, J.)

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