AMISUB (SFH), INC., dba Saint Francis Hospital; Saint Francis Hospital-Bartlett, Inc. v. CIGNA HEALTH AND LIFE INSURANCE COMPANY - Articles

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AMISUB (SFH), INC., dba Saint Francis Hospital; Saint Francis Hospital-Bartlett, Inc. v. CIGNA HEALTH AND LIFE INSURANCE COMPANY

Posted by: Azya Thornton on Jul 1, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: Jonathan E. Siegelaub, LASH & GOLDBERG, LLP, Miami, Florida, for Appellants.

Attorneys 2: ARGUED: Warren Haskel, MCDERMOTT WILL & EMERY LLP, New York, New York, for Appellee.

Attorneys 3: ON BRIEF: Jonathan E. Siegelaub, Greg J. Weintraub, LASH & GOLDBERG, LLP, Miami, Florida, Robert E. Cooper, David R. Esquivel, Sara K. Morgan, BASS, BERRY & SIMS PLC, Nashville, Tennessee, for Appellants.

Attorneys 4: ON BRIEF: Warren Haskel, Joshua B. Simon, Dmitriy Tishyevich, John J. Song, MCDERMOTT WILL & EMERY LLP, New York, New York, for Appellee.

Judge(s): CLAY, BUSH, and BLOOMEKATZ, Circuit Judges

Court Appealed: United States District Court for the Western District of Tennessee at Memphis

JOHN K. BUSH, Circuit Judge. Saint Francis Hospital and Saint Francis Hospital- Bartlett (Hospitals), based in Tennessee, brought claims purporting to rely on their state’s common law for quantum meruit and unjust enrichment against Cigna Health and Life Insurance Company, a Connecticut-based insurer. The Hospitals claim that Cigna, under its health insurance policies, routinely pays less than reasonable value when the Hospitals provide emergency care to Cigna members. The Hospitals have no contract with Cigna constraining the amount the Hospitals can charge Cigna’s members for emergency services. In other words, the Hospitals are, in insurance parlance, “out-of-network.” Nonetheless, the Hospitals argue they have a quasi-contractual relationship with Cigna requiring it to pay more for emergency care than what its health insurance contracts provide. They base their argument on federal and state law requiring both that hospitals treat all emergency patients who need their care and that insurers cover emergency care. Essentially, the Hospitals believe Cigna has a duty to pay the full value of their services regardless of whether Cigna contracted with its members to limit its liability.

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