Hudson Neurosurgery, PLLC v. Archdiocese of New York

Background

Hudson Neurosurgery, PLLC, a private neurosurgery practice, sued the Archdiocese of New York on an unjust enrichment theory. The claim arose from cervical surgery that Dr. Haroon F. Choudhri performed on a patient who was an eligible dependent under a group health plan sponsored by the Archdiocese. Hudson Neurosurgery was out of network with insurers other than Medicare.

The practice requested prior authorization from UnitedHealthcare, which denied authorization because the practice was out of network and the patient lacked out-of-network benefits. After the surgery, Hudson Neurosurgery submitted claims totaling $498,842. On November 15, 2021, it signed a Single Case Agreement with Medical Audit & Review Solutions. The agreement stated that Hudson Neurosurgery would accept the proposed amount, up to $98,320 subject to specified deductions, would not bill the patient for the balance, and would reduce the liability of the patient and the payor. UnitedHealthcare later paid $29,116.67.

Summary-judgment standard

The Archdiocese moved for summary judgment, which is a ruling without a trial when the evidence shows that no genuine dispute over an important fact exists and the moving party is entitled to judgment under the law. The court must view the evidence favorably to the party opposing the motion and may not resolve competing factual inferences at this stage.

Contract ruling

New York unjust enrichment is a claim seeking restitution when the defendant benefited at the plaintiff’s expense and fairness requires repayment. Ordinarily, an enforceable contract covering the same subject matter prevents recovery under unjust enrichment, even when one party to the lawsuit is not a party to that contract.

The court held as a matter of law that Hudson Neurosurgery and UnitedHealthcare formed a binding, unambiguous contract through the Single Case Agreement and UnitedHealthcare’s subsequent payment. The court rejected Hudson Neurosurgery’s arguments that the agreement lacked mutual obligations, was illusory, or had an indefinite payment term. The agreement exchanged UnitedHealthcare’s promise to pay up to the proposed amount for Hudson Neurosurgery’s promises not to balance-bill the patient and to reduce the patient’s and payor’s liability. The court also held that the Archdiocese did not need to be a party to the agreement for the contract to preclude an unjust enrichment claim.

Emergency-care issue

Hudson Neurosurgery argued that the surgery was required by the Emergency Medical Treatment and Labor Act, a federal law requiring hospitals to stabilize or transfer patients with emergency medical conditions. The court found persuasive authority treating emergency medical care as potentially supporting an unjust enrichment claim against an insurer or other responsible party, even when the provider is a private physician rather than a hospital.

The parties sharply disputed whether the patient’s surgery was elective or emergent. The Archdiocese relied on evidence that other doctors did not determine that the patient had an emergency medical condition. Hudson Neurosurgery relied in part on Dr. Choudhri’s opinion that the patient needed immediate relief, along with his testimony about the patient’s severe pain and impaired right arm. The court concluded that a reasonable jury could interpret the record either way, so the dispute could not be resolved on summary judgment.

The court noted that it had found no case involving an unjust enrichment claim by a medical provider against a health-plan sponsor, rather than an insurer. It assumed, without deciding, that a plan sponsor could be liable in these circumstances.

Disposition

The court’s conclusion states that the Archdiocese’s motion for summary judgment was denied in part and granted in part. The contract ruling granted the Archdiocese judgment on the effect of the Single Case Agreement, while the factual dispute over whether the surgery was emergency treatment prevented summary judgment on that ground. The court scheduled a telephonic status conference for October 9, 2025.