Wednesday, December 4, 2013

Sisters of St. Joseph of Peace, Health, and Hospital Services v. Russell

Sisters of St. Joseph of Peace, Health, and Hospital Services v. Russell case brief summary
867 P.2d 1377 (1994)


CASE SYNOPSIS
Defendant insurer sought review of a decision from the Lane County Circuit Court (Oregon), denying defendant's motion for directed verdict as to plaintiff hospital's claim for payment of medical services plaintiff provided to defendant injured worker. The jury found that plaintiff was a third-party beneficiary to a worker's compensation disputed claim agreement to which defendants were parties.

CASE FACTS
Defendant insurer challenged the trial court's refusal to grant its motion for a directed verdict after a jury found defendant liable for reimbursing plaintiff hospital for the cost of medical care provided to defendant injured worker. Not long after defendant worker's accident, he and defendant insurer had entered into a worker's compensation disputed claim settlement agreement under Or. Rev. Stat. § 656.289(4). The jury found that defendant insurer was obligated to reimburse plaintiff because plaintiff was a third-party beneficiary to that agreement.

DISCUSSION

  • On appeal, the state's highest court held that by the time defendants' settlement agreement was signed, plaintiff had already provided something of value to defendant worker, i.e., medical treatment, making plaintiff a creditor beneficiary of the agreement as long as defendants intended to benefit plaintiff. 
  • The court held that they had. In the agreement, defendants split the financial responsibility for defendant worker's care, defendant insurer being responsible for defendant worker's past but not future medical bills. 
  • The court affirmed the trial court's denial of defendant insurer's motion for directed verdict.

CONCLUSION
The court affirmed the trial court's denial of a directed verdict in favor of defendant insurer after a jury found defendant liable for paying plaintiff hospital for defendant injured worker's past medical bills because plaintiff was a third-party beneficiary of a worker's compensation disputed claim settlement agreement signed by two defendants.

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