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U.S. Court of Appeals for the Tenth Circuit Upholds Dismissal of Plaintiffs’ Complaint Challenging Fees Charged by New Mexico Medical Center
In a recent ruling, the U.S. Court of Appeals for the Tenth Circuit affirmed the dismissal of a putative class action brought by plaintiffs seeking to challenge bills for medical services. Allegedly the plaintiffs received medical services at a medical center in New Mexico and were charged unreasonable and excessive fees. They brought a complaint in state court asserting negligence and breach of contract claims against entities they asserted were responsible for the billing for medical services.
The defendants removed the complaint from state court to the U.S. District Court for the District of New Mexico then filed a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). The District Court granted the defendants’ dismissal motion, concluding that the plaintiffs failed to allege a duty or injury sufficient to support a claim for negligence and failed to plead sufficient facts giving rise to an implied contract. The plaintiffs appealed to the U.S. Court of Appeals for the Tenth Circuit.
The Court of Appeals explained at the outset of its analysis that it was applying a de novo legal standard. The Court also observed that, because the plaintiffs’ claims arose under state law, the Court was to apply New Mexico law to achieve the result that would be reached in a New Mexico court.
First, the Court of Appeals considered whether the plaintiffs’ negligence claims were properly dismissed. The Court assumed for analytical purposes that the defendants could owe the plaintiffs a duty of care because they contracted with the medical center to staff the emergency room with physicians and controlled the physicians that treated the plaintiffs. However, the Court criticized the plaintiffs’ theory of recovery, asserting the plaintiffs were unable to cite authority suggesting that a doctor’s duty to provide competent medical care requires entities that employ doctors to charge an unspecified reasonable fee.
The Court further reasoned that a broad concept of duty under New Mexico law does not transform all perceived wrongs into negligence claims and that the plaintiffs did not state a claim for negligence based on allegations of having been billed at unreasonable rates, causing the plaintiffs to pay bills that were too high and, in some cases, damaging their financial stability and credit ratings. Based on its review of the record, the Court affirmed the dismissal of the negligence claims. The Court also affirmed the dismissal of the plaintiffs’ contractual claims and claims of unconscionability.
If you or a loved one has been hurt in an accident, there may be grounds for a financial recovery. Receiving money damages can help injured people and their families recover out-of-pocket costs including medical bills and lost wages. To understand more about your case and how it can be pursued to maximize your financial recovery, call New Mexico personal injury lawyer Matthew Vance. At the Law Office of Matthew Vance, P.C., we provide a free consultation and can be reached at (505) 242-6267 or send us a message online.
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