Hamilton Mem’l Hosp. Dist. v. Toelle (Summary)

BREACH OF CONTRACT

Hamilton Mem’l Hosp. Dist. v. Toelle, No. 12-cv-1004-JPG-PMF (S.D. Ill. Apr. 11, 2014)

The United States District Court for the Southern District of Illinois granted in part and denied in part a motion for summary judgment filed by a physician in a hospital’s lawsuit for breach of contract.

A physician (“Physician”) left the employment of a hospital (“Employer”) in the middle of a three-year contract, in order to work for another hospital.  The Employer filed suit, arguing that it was entitled to damages for the costs associated with tail insurance, a signing bonus and moving expenses for a replacement physician, loss of goodwill, and expenses associated with continuing medical education (“CME”).  The Physician filed a motion for summary judgment to dismiss the claim for damages brought by the Employer.

The employment agreement required the Employer to cover the cost of tail insurance unless there was a “for cause” termination.  The court concluded that no reasonable jury could find the Physician liable for the price of the tail insurance in light of the Physician’s early departure.  The court also found that the Employer failed to provide evidence to support its claim for loss of goodwill.  The court also found that the CME expenses fell within the category of expenses that the Employer was obligated to pay, per the employment contract.  Summary judgment was granted on behalf of the Physician for these claimed damages.

The Employer had also claimed that the Physician should reimburse the amount spent to recruit a replacement physician, as well as the amount paid to the replacement physician for a signing bonus and moving costs.  With respect to these claims, the court found that there was a genuine issue of fact, and the Physician’s motion for summary judgment was denied.