Lucile Salter Packard Children's Hospital at Stanford v. Blue Cross Blue Shield…
Lucile Salter Packard Children's Hospital at Stanford v. Blue Cross Blue Shield Healthcare Plan of Georgia, Inc.
- Edward Chen
- 3:21-cv-09606
- U.S. District Court · Northern District of California
- 4
In Lucile Salter Packard Children's Hospital v. Blue Cross Blue Shield Healthcare Plan of Georgia, Judge Chen granted the University Defendants’ dismissal motion based on Eleventh Amendment immunity.
The order directly affected Lucile Salter Packard Children’s Hospital at Stanford, the Board of Regents of the University System of Georgia, and the Georgia Institute of Technology. It granted the Board’s and Georgia Tech’s motion to dismiss and entered judgment in their favor; the opinion does not state a disposition concerning Blue Cross Blue Shield Healthcare Plan of Georgia, Inc.
What happened
Lucile Salter Packard Children’s Hospital at Stanford sued Blue Cross Blue Shield Healthcare Plan of Georgia, the Board of Regents of the University System of Georgia, and the Georgia Institute of Technology. The hospital sought payment for services provided to a patient and relied on an implied contract and a payment-for-services theory.
The Board and Georgia Tech asked the court to dismiss the claims against them. They argued that the Eleventh Amendment protected them from suit in federal court and also raised arguments about diversity jurisdiction and another issue that is not fully shown in the provided text.
The court ruled that the Board and Georgia Tech are treated as parts of the State of Georgia and therefore have Eleventh Amendment immunity. Judge Edward M. Chen granted their motion to dismiss, entered judgment in their favor, and did not decide whether the hospital’s contract claim was valid.
The detailed version
- Lucile Salter Packard Children's Hospital at Stanford v. Blue Cross Blue Shield… · No. 3:21-cv-09606
- Edward Chen
- Oct. 4, 2022
Background
Lucile Salter Packard Children’s Hospital at Stanford sued Blue Cross Blue Shield Healthcare Plan of Georgia, Inc., the Board of Regents of the University System of Georgia, and the Georgia Institute of Technology. The hospital alleged that it was owed payment for services provided to a non-party patient, identified as Patient D. It based its claims on quantum meruit, a theory seeking payment for the reasonable value of services, and breach of an implied-in-fact contract, meaning a contract inferred from the parties’ conduct rather than expressed in writing.
The Board of Regents and Georgia Tech, identified in the opinion as the University Defendants, moved to dismiss under Federal Rule of Civil Procedure 12(b)(6). That rule allows dismissal when a complaint does not adequately state a claim for relief. The University Defendants argued that the Eleventh Amendment barred the hospital’s claims against them and also raised arguments concerning diversity jurisdiction. The provided opinion text does not fully show the University Defendants’ third argument.
Analysis
The court addressed the Eleventh Amendment issue. That amendment generally protects a state and certain state agencies or instrumentalities from lawsuits brought by private parties in federal court unless the state has consented to the suit or an exception applies.
The court concluded that the Board of Regents and Georgia Tech are arms of the State of Georgia. Relying on decisions characterizing the Board and Georgia’s public universities as state entities, the court held that the University Defendants were entitled to Eleventh Amendment immunity. The court therefore did not address the validity of the hospital’s underlying contract claim.
Disposition
The court granted the University Defendants’ motion to dismiss. It found that the hospital’s suit against those defendants was barred by the Eleventh Amendment, instructed the Clerk to enter judgment in favor of the University Defendants, and stated that the order disposed of Docket No. 32. The opinion does not state whether the dismissal was with or without prejudice.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.