Milford Hosp. v. Champeau

Milford Hosp. v. Champeau,
No. CV00069269S (Conn. Super. Ct. April 27, 2001)

A Connecticut hospital brought an action against an emergency room patient
seeking payment for hospital charges under the theories of quantum merit, unjust
enrichment, principal-agent liability, and ?46b-37 of the General Statutes of
Connecticut, which imposes a joint duty on each spouse to support his or her
family. The patient raised two special defenses, alleging (1) that he did not
owe the hospital the amount charged because the hospital?s fees were excessive
and unreasonable, and (2) that the signed agreement to pay hospital charges
was void and unenforceable because his wife signed the agreement under duress.

In response to the patient?s first special defense, the Superior Court of Connecticut
found that the patient?s allegations of "unreasonableness" were insufficient
as the "reasonableness" of the charges relates to damages and is not
an element of the theories of quantum merit or unjust enrichment. Additionally,
the court held that the statutory language in ?46b-37(b) does not require a
showing of reasonableness or necessity for hospital expenses. The court also
rejected the patient?s defense that his wife signed the hospital?s authorization
agreement under duress, ruling that the hospital?s agreement requiring payment
for hospital services was not unfair to the patient.