Stanford Health Care v. Trustmark Services Company

Background

The court had previously granted the defendants’ motions to dismiss Stanford Health Care’s Second Amended Complaint. The court dismissed the breach-of-contract and quantum-meruit claims with prejudice, meaning those claims could not be refiled. It also dismissed Stanford Health Care’s claim under California’s Unfair Competition Law, but allowed amendment to the extent Stanford Health Care could seek a remedy available under that law.

Stanford Health Care then filed a Third Amended Complaint. The opinion states that the Third Amended Complaint did not include an Unfair Competition Law claim.

Court’s Ruling

The court stated that Stanford Health Care had been given ample opportunities to state a claim and had received multiple explanations of why its claims were inadequately pleaded. Because Stanford Health Care had repeatedly failed to do so, the court concluded that another round of motion practice was unnecessary and that there was no reason to permit a fourth amended complaint.

The court therefore dismissed the Third Amended Complaint on its own initiative, with prejudice. It ordered that a separate judgment enter and that the case be closed. The court also stated that the possibility that health plans might avoid paying some bills did not relieve Stanford Health Care of its obligation to state a legally viable claim for which the court could grant relief. It noted that Stanford Health Care appeared able to seek recovery from individual patients, who could then seek recovery from Chef’s Warehouse if that entity had not paid the correct amount under the health plan.