Justia Health Law Opinion SummariesArticles Posted in Supreme Court of Indiana
FMS Nephrology Partners North Central Indiana Dialysis Centers, LLC v. Meritain Health, Inc.
The Supreme Court vacated the trial court's grant of summary judgment for Defendants, holding that the trial court erred by entering summary judgment for defendant health-insurance plans, which were governed by the Employee Retirement Income Security Act of 1974 (ERISA), based on ERISA preemption.Plaintiff, a health-care provider, contracted with two third-party networks. Defendants and its affiliated employee health-insurance plans contacted with both health networks. Seven patients received treatments from Plaintiff, and the patients were covered under Defendants' plans. Plaintiff sued Defendants, alleging that they failed to pay agreed reimbursement rates for covered services under their plans. The trial court granted summary judgment against Plaintiff, concluding that Plaintiff's claims were preempted under ERISA's conflict-preemption provision, 29 U.S.C. 1144(a). The Supreme Court vacated the judgment, holding that genuine issues of disputed fact existed concerning the central issue of whether the provider's claims were denied coverage under the plans or whether the provider's claims necessitated interpreting the plan documents. View "FMS Nephrology Partners North Central Indiana Dialysis Centers, LLC v. Meritain Health, Inc." on Justia Law
In re Civil Commitment of T.W. v. St. Vincent Hospital & Health Care Center, Inc.
In these two mental health cases, the Supreme Court dismissed the appeals of the temporary commitment orders of two individuals, holding that the Probate Commissioner lacked authority to enter the commitment orders.Although the appeals were moot, the Supreme Court addressed an issue of great public importance likely to recur, that issue being whether the Commissioners lacked authority to enter the orders of civil commitment. On appeal, Appellants argued that, rather than issuing a commitment order, the Commissioner approved each order via an "approval order" that did not constitute valid commitment orders for these two mental health cases. The Supreme Court agreed, holding that the approval orders provided inadequate assurance that the Commissioner was presented with, reviewed, and approved the temporary commitment orders in the cases of the two individuals at issue here. View "In re Civil Commitment of T.W. v. St. Vincent Hospital & Health Care Center, Inc." on Justia Law
A.A. v. Eskenazi Health/Midtown CMHC
In this involuntary civil commitment proceeding, the trial court accepted an invalid waiver of A.A.’s right to personal appear, and that error was not harmless.A.A.’s attorney waived A.A.’s right to appear, and the involuntary commitment hearing proceeded without him. The trial court ultimately ordered involuntary civil commitment. The Supreme Court reversed and remanded for the trial court to vacate the regular involuntary-commitment order, holding (1) a mentally competent civil-commitment respondent may relinquish the right to appear with a knowing, voluntary, and intelligent waiver, but an attorney may not waive the right to appear on the respondent’s behalf; (2) if the trial court independently waives a respondent’s presence at a commitment hearing, it must do so at the outset of the proceeding; (3) an improper waiver determination is subject to harmless-error review; and (4) in this case, the trial court did not make a proper waiver finding at the outset of A.A.’s involuntary civil-commitment proceeding, and the error was not harmless. View "A.A. v. Eskenazi Health/Midtown CMHC" on Justia Law