Hefczyz v. Rady Children’s Hosp.

Artur Hefczyc appealed an order denying his motion for class certification in his lawsuit against Rady Children's Hospital-San Diego (Rady). On behalf of a proposed class, Hefczyc sought declaratory relief to establish that Rady's form contract, signed by patients or guarantors of patients who receive emergency room care, authorized Rady to charge only for the reasonable value of its services, and that Rady therefore was not authorized to bill self-pay patients based on its master list of itemized charge rates, commonly referred to as the "Chargemaster" schedule of rates, which Hefczyc alleged was "artificial" and "grossly inflated." The trial court denied Hefczyc's motion for class certification, concluding that the class was not ascertainable, that common issues did not predominate, and that class action litigation was not a superior means of proceeding. Hefczyc contends that the trial court erred in denying class certification because, as the complaint sought only declaratory relief, the motion for class certification was brought under the equivalent of Federal Rules of Civil Procedure, rule 23(b)(1)(A) or (b)(2) (28 U.S.C.), for which he was not required to establish the ascertainability of the class, that common issues predominated and that class action litigation was a superior means of proceeding. Hefczyc also contended that even if the trial court properly imposed those three requirements in this action, the trial court abused its discretion in concluding that those requirements were not met. After review, the Court of Appeal concluded that Hefczyc's arguments lacked merit, and accordingly affirmed the order denying class certification. View "Hefczyz v. Rady Children's Hosp." on Justia Law