U.S. Health Practices, Inc. v. Byron Blake M.D., Inc.
No. 00AP-1002 (Ohio Ct. App. Mar. 22, 2001)

U.S. Health sued a private physician for unjust enrichment and quantum meruit after it paid the salary of a U.S. Health doctor who was working in the private physician’s office for over one year. The situation arose as a result of an agreement between U.S. Health and the private physician. The relationship deteriorated and the agreement was canceled, but the U.S. Health doctor continued to work in the private doctor’s office, and U.S. Health continued to pay her salary for over one year after the agreement was terminated.

The Ohio Court of Appeals upheld the lower court’s ruling based on the fact that U.S. Health was unable to show that the private physician received a benefit under the totality of the circumstances because he paid for equipment, office space, administrative services, extra staff, and medical supplies for the U.S. Health doctor without ever being compensated by U.S. Health, U.S. Health maintained a presence in the geographic area, and U.S. Health added several hundred patients to its base after its doctor left the private physician’s office. The court of appeals also found that U.S. Health was at least partially at fault for the situation.