Express Recovery Services Inc. v. Reuling

Citations: 2015 UT App 299; 364 P.3d 766; 802 Utah Adv. Rep. 28; 2015 Utah App. LEXIS 315; 2015 WL 9256860Docket: 20141032-CA

Court: Court of Appeals of Utah; December 17, 2015; Utah; State Appellate Court

Original Court Document: View Document

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Richard Reuling Jr. and Margaret Reuling (Appellants) appeal a judgment from the Third District Court favoring Express Recovery Services Inc. (Appellee) regarding medical debt incurred from Richard's treatment at the University of Utah Health Care (UUHC) following a severe car accident in 2011. After failing to pay the owed amount, which totaled $27,600.78, Appellants had their account assigned to ERS, which subsequently attempted to collect the debt. Despite acknowledging their liability for the medical costs, Appellants disputed the amount claimed by ERS, arguing that the hospital's billing was unclear and potentially erroneous. 

During the trial, Appellants asserted that the bills were difficult to understand and contended that the hospital did not fulfill its obligation to provide accurate billing. However, the trial court ruled that the charges were reasonable and adequately detailed. It ultimately awarded ERS $25,742.00, plus statutory interest, totaling $26,895.00. Following the judgment, Appellants filed a motion to amend the findings, which the court denied. ERS argued that the appeal should be dismissed due to jurisdictional issues, as Appellants’ motion was deemed a motion to reconsider, not tolling the appeal period.

On September 18, 2014, the trial court denied Appellants’ motion, which ERS argued was essentially a motion to reconsider, based on a September 2, 2014 hearing that is not recorded in the appeal record. The September 18 order did not reference the reconsideration aspect. ERS sought to correct this order, leading to a revised order on October 31, 2014, clarifying that Appellants’ motion was indeed a motion to reconsider, which was denied based on previous rulings. Under rule 4(b) of the Utah Rules of Appellate Procedure, the timeline for filing an appeal is paused by certain postjudgment motions, including those to amend findings or for a new trial. The Utah Supreme Court has ruled that motions to reconsider do not toll the appeal period. ERS contended that Appellants had thirty days from the final judgment on June 27, 2014, to appeal, but Appellants filed their notice of appeal on October 13, 2014, which was within the timeframe following the September order. Although the trial court ultimately categorized Appellants’ motion as a motion to reconsider, it was concluded that Appellants timely filed their appeal based on the September 18 order. Additionally, Appellants argued that the trial court applied an incorrect standard of proof in granting judgment to ERS in quantum meruit, claiming insufficient evidence regarding the specific services and their reasonable value undermined ERS’s entitlement to recovery under this theory.

A determination of unjust enrichment involves both legal and factual considerations, with trial court findings upheld unless clearly erroneous. Broad discretion is granted to trial courts in applying unjust enrichment law. Quantum meruit, an equitable remedy, allows a plaintiff to recover the reasonable value of services provided to a defendant. It encompasses two branches: contracts implied in law and contracts implied in fact, with the relevant branch here being contracts implied in law, also known as quasi-contracts. To establish a contract implied in law, the plaintiff must demonstrate that the defendant received a benefit, recognized this benefit, and retained it in a manner that would be unjust without compensation.

In this case, both parties acknowledged that Richard received necessary medical care and understood that he should pay for it, leading to a consensus on the existence of a contract implied in law. The disagreement lies in the amount of damages, with Appellants arguing that ERS could not substantiate the specific goods and services provided or their reasonable value. However, the court rejected this claim, citing a recent Utah Supreme Court ruling that emphasizes the recovery measure for unjust enrichment claims as the value of the benefit conferred. In scenarios involving professional services, the benefit's value typically aligns with the service's reasonable value.

The trial court assessed the value of UUHC's services based on testimony from its collections office supervisor and billing information. The supervisor indicated that UUHC's charges reflect regional norms and that the charges were medically reasonable, further noting a 30 percent discount given to Richard for being uninsured.

The supervisor testified that Richard was assigned two account numbers by the hospital: Account 21 for facility charges and Account 90 for doctor charges. The trial court determined that the initial bill for Account 21, dated September 28, 2011, totaled $18,847.00, with detailed charges from various hospital departments and a care discount of $8,077.47. An additional charge on October 30, 2011, for cardiac monitoring raised the total for Account 21 to $18,913.00, with a subsequent discount of $28.20. For Account 90, the first bill on October 2, 2011, was for $3,638.00, and additional charges on November 6, 2011, and January 15, 2012, increased the total to $6,829.00. A charge of $469.00 for a chest tube insertion on July 7, 2012, was deemed excessively late and unreasonable. The trial court ruled in favor of Express Recovery Services (ERS) for a total of $26,895.00, which included $25,742.00 for medical services and statutory interest of $1,153.00. The appellants did not dispute the damage computation but questioned the value of the services provided. However, the court clarified that the appropriate measure of damages is the reasonable value of the services rendered. The evidence supported the trial court's findings that UUHC provided $25,742.00 worth of medical services to Richard, with billing statements and testimony indicating that these values were based on regional standards and included discounts for uninsured patients. Ultimately, the court upheld the trial court’s calculation of damages under quantum meruit, affirming the award based on the reasonable value of the services provided.

Appellants argue that the lack of an itemized statement prevents determining the reasonable value of the goods and services ERS seeks to recover, but this claim is rejected. The court acknowledges that while billing statements could have been more detailed, uncertainty in damage evidence does not absolve a defendant from compensating a plaintiff. The court refers to prior cases affirming that the sufficiency of evidence, rather than its perfection, is the focus on appeal. Despite Appellants' claim that Richard did not receive an itemized statement, the record shows forty-seven pages of itemized statements were initially disclosed to ERS, detailing service dates, codes, descriptions, quantities, and charges, although they were not presented to the trial court.

Appellants also argue that the trial court erred in denying their motions to amend findings and judgment under Rules 52(b) and 59(a), claiming insufficient evidence existed for the court to support its judgment. The court reviews the denial for abuse of discretion and notes that Rule 52 allows amendments within 14 days of judgment. Findings based on evidence shall not be set aside unless erroneous, taking into account the trial court's credibility assessments. The trial court set forth specific facts supporting its judgment, and sufficient evidence was presented at trial to back its findings, which are not clearly erroneous. Consequently, Appellants' argument under Rule 59 fails as well, leading to the conclusion that the trial court did not abuse its discretion in denying the motions. The trial court's judgment is affirmed.