Abby Allen and Walter Moore v. Clarian Health ... - State of Indiana

immune from medical billing claims unless our legislature expressly authorizes such
claims.
Clarian‟s suggestion that the Indiana judiciary is not an appropriate forum for
adjudicating reasonable medical expenses was squarely rejected by our supreme court‟s
decision in Stanley.
Again, the court expressly concluded, albeit in the context of
personal injury law, that Indiana‟s courts and jurors are quite capable of determining
reasonable medical expenses. Stanley, 906 N.E.2d at 856-57. And it has long been the
judiciary‟s function to determine a reasonable charge when a contract lacks a definite
provision for payment. See, e.g., Hubbard, 18 N.E. at 612. We recognize that medical
billing is complicated, see Stanley, 906 N.E.2d at 857, but that does not change the fact
that this is a basic breach of contract case guided by well-established Indiana law. We
have found no Indiana authority supporting the proposition that medical expenses and
billing are or should be exempt from the common law.
Conclusion
In sum, the trial court erred when it granted Clarian‟s Rule 12(B)(6) motion to
dismiss the complaint for failure to state a claim upon which relief can be granted. Allen
and Moore stated a claim for breach of contract under the Indiana Declaratory Judgments
Act. More than a century of legal precedent, including recent Indiana Supreme Court
authority, provides the proper legal framework for our conclusion that Allen and Moore
have stated a claim for breach of contract upon which relief can be granted. The trial
court‟s decision is reversed and this cause is remanded for further proceedings.
Reversed and remanded.
ROBB, C.J., and BAILEY, J., concur.
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