Judge: Armen Tamzarian, Case: 24STCV15242, Date: 2024-10-03 Tentative Ruling

Case Number: 24STCV15242    Hearing Date: October 3, 2024    Dept: 52

Tentative Ruling

Defendants Blue Shield of California Life & Health Insurance Company and California Physicians’ Service dba Blue Shield of California’s Demurrer

Defendants Blue Shield of California Life & Health Insurance Company and California Physicians’ Service dba Blue Shield of California demur to all 14 causes of action alleged by plaintiff DoctorNow, Inc.

Request for Judicial Notice

Plaintiff requests judicial notice of an order by the superior court in another case.  The order is not relevant or necessary to the court’s analysis.  (See Jordache Enterprises, Inc. v. Brobeck, Phleger & Harrison (1998) 18 Cal.4th 739, 748, fn. 6; Appel v. Superior Court (2013) 214 Cal.App.4th 329, 342, fn. 6.) 

Plaintiff’s request for judicial notice is denied.

1st Cause of Action: Unfair Competition Law

            Defendants’ papers do not clearly demur to the first cause of action.  They refer to plaintiffs’ cause of action for violation of Health and Safety Code section 1342.2 as the “first cause of action.”  (Memo, pp. 3-4.)  It is not the first cause of action.  It is the 11th cause of action.  (The body of the complaint erroneously has two seventh causes of action and therefore incorrectly labels violation of Health and Safety Code section 1342.2 the 10th cause of action.)  The first cause of action alleges violation of the unfair competition law. 

Assuming defendants meant to demur to the first cause of action, plaintiff alleges sufficient facts for unfair competition.  Defendants argue only that Health and Safety Code section 1342.2 does not provide a private right of action.  Even if correct, that is irrelevant to the first cause of action.  The unfair competition law “ ‘borrows’ violations from other laws by making them independently actionable as unfair competitive practices.”  (Korea Supply Co. v. Lockheed Martin Corp. (2003) 29 Cal.4th 1134, 1143.)  “[A] private plaintiff may bring a UCL action even when ‘the conduct alleged to constitute unfair competition violates a statute for the direct enforcement of which there is no private right of action.’ ”  (Kasky v. Nike, Inc. (2002) 27 Cal.4th 939, 950.)

2nd Cause of Action: Negligence

            Plaintiff does not allege sufficient facts for the element of duty.  “[T]here is no legal duty” in tort “not to negligently or intentionally underreimburse a hospital or other medical provider.”  (Long Beach Memorial Medical Center v. Kaiser Foundation Health Plan, Inc. (2021) 71 Cal.App.5th 323, 341 (Long Beach Memorial).)  Imposing a tort duty “not to underreimburse” a medical provider “runs afoul of the longstanding principle that tort ‘liability … for purely economic losses is “the exception, not the rule.” ’ ”  (Id. at pp. 337-338.) 

Plaintiff’s second cause of action alleges defendants violated statutory duties requiring them “to reimburse DoctorNow … the cash prices for COVID Testing listed on DoctorNow’s public internet website.”  (Comp., ¶ 102.)  That is equivalent to the legal duty the Court of Appeal rejected in Long Beach Memorial. 

Plaintiff’s reliance on Centinela Freeman Emergency Medical Associates v. Health Net of California, Inc. (2016) 1 Cal.5th 994 (Centinela) is misplaced.  In Centinela, the California Supreme Court recognized a duty “to fill a gap in the provisions of the Knox-Keene Act that would have otherwise allowed health plans to make reckless—and hence ‘morally blameworthy’—delegations of the duty to pay and thereby to leave hospitals and other medical providers ‘without any reasonable prospect of payment’ despite their statutory entitlement to such remuneration.”  (Long Beach Memorial, supra, 71 Cal.App.5th at pp. 340-341.)  Centinela did not purport to create a free-floating tort duty attaching to every provision of the Knox-Keene Act, including those where there is no gap, such as in the context of this case, where the hospitals and other medical providers already have the right to sue for quantum meruit to recover any underpayment.”  (Id. at p. 341.) 

Centinela is distinguishable from the present case.  There, the court held “a health care service plan may be liable to noncontracting emergency service providers for negligently delegating its financial responsibility to an IPA or other contracting medical provider group that it knew or should have known would not be able to pay for emergency service and care provided to the health plan's enrollees.”  (Centinela, supra, 1 Cal.5th at pp. 1001-1002.)  Under the Knox-Keene Act, the plaintiff providers in Centinela were obligated to provide emergency services regardless of whether there was a reasonable prospect of being paid for their services.  By contrast, plaintiff DoctorNow, Inc. had no obligation to provide its services.  DoctorNow, Inc. was free to refuse services to defendant’s insureds unless and until defendant negotiated a contract.  Further, if plaintiff persuades the trier of fact that defendant violated Health and Safety Code section 1342.2, it has a remedy under the Unfair Competition Law.  Likewise, as explained below, if plaintiff persuades the trier of fact that defendant made certain false promises, plaintiff may seek damages pursuant to its fraud and promissory estoppel causes of action.  Accordingly, there is no gap that needs to be filled by recognizing a tort duty.

3rd Cause of Action: Fraud

            Plaintiff alleges sufficient facts for this cause of action.  Fraud by intentional misrepresentation requires: (1) a misrepresentation of fact; (2) knowledge of falsity; (3) an intent to defraud; (4) justifiable reliance; and (5) damages.  (Ryder v. Lightstorm Entertainment, Inc. (2016) 246 Cal.App.4th 1064, 1079.)  “[F]raud must be pled specifically.”  (Lazar v. Superior Court (1996) 12 Cal.4th 631, 645.)  “ ‘This particularity requirement necessitates pleading facts which show how, when, where, to whom, and by what means the representations were tendered.’ ”  (Ibid.)  “A plaintiff’s burden in asserting a fraud claim against a corporate employer is even greater.  In such a case, the plaintiff must ‘allege the names of the persons who made the allegedly fraudulent representations, their authority to speak, to whom they spoke, what they said or wrote, and when it was said or written.’ ”  (Ibid.) 

            Plaintiff specifically alleges each element.  Plaintiff alleges the misrepresentation occurred in an email from “Joan Russo, Senior Manager of Regulatory Filing.”  (Comp., ¶ 118.)   Plaintiff alleges that on August 16, 2021, Russo sent plaintiff an email stating: “[T]he Plan does not dispute that we are mandated to cover an out-of-network claim for eligible COVID diagnostic testing services based on the provider’s posted cash price.  We have requested that our Claims department complete an audit of all claims submitted by DoctorNow for the above referenced testing procedures and to reprocess any claims that have been incorrectly denied or paid based on an allowance other than the posted cash price.”  (Id., Ex. B, p. 2.)  The email further included a table of various CPT codes and columns labeled “Posted Price” and “Payment Required @ Posted Price.”  (Id., p. 3.)  In the row for the relevant CPT code for COVID testing, the table provides the “Posted Price” was “$295” and “YES”, payment at the posted price was required.  (Id. at p. 4.)

            Plaintiff alleges, “Relying on these statements DoctorNow continued to provide services to Defendants’ Insureds.  From August 17, 2021, the day after the representation, to May 11, 2023, the end of the Federal Public Health Emergency, DoctorNow performed approximately 85,000 tests for Defendant’s Insureds, relying on these representations.”  (Comp., ¶ 121.)  Plaintiff alleges it suffered damages because “Defendants abandoned the published cash price policy and began denying claims as well as underpaying thousands of claims” totaling a balance of “$22,995,866.83.”  (Ibid.)       

Defendants argue, “The complaint does not plausibly allege knowingly false statements made with the intent to defraud Plaintiff.”  (Memo, p. 6.)  Unlike federal court proceedings, California civil procedure has no plausibility requirement for pleading.  The court must accept factual allegations as true regardless of whether the court finds them plausible.  (Hacker v. Homeward Residential, Inc. (2018) 26 Cal.App.5th 270, 280 [on demurrer, “the facts alleged in the pleading are deemed to be true, however improbable they may be”].)  Allegations of knowledge and intent are ultimate facts sufficient to withstand challenge by demurrer.  (See, e.g., Perkins v. Superior Court (1981) 117 Cal.App.3d 1, 6 [allegations that defendants acted “wrongfully and intentionally” and “in retaliation” sufficient to support prayer for punitive damages]; Johnson v. Casetta (1961) 197 Cal.App.2d 272, 276 [“an allegation of knowledge of incompetency is an allegation of ultimate fact”]; Rosin v. Superior Court (1960) 181 Cal.App.2d 486, 490 [“It has been suggested that the allegation of petitioner’s intent in removing the children from the jurisdiction is only a conclusion. . . .  This is an allegation of fact, not a mere conclusion.”].)

            Defendants further argue plaintiff did not adequately allege Russo’s authority to speak on behalf of the entity defendants.  Plaintiff alleges sufficient facts to withstand demurrer.  It alleges Russo was “Senior Manager of Regulatory Filing.”  (Comp., ¶ 118.)  In her email to plaintiff, she wrote that her “earlier response was premature as we had not yet finished our audit and consideration of your claims.  [¶]  Please accept the attached version as our final response.”  (Comp., Ex. B, p. 1.)  Giving a “final response” to supersede a “premature” response made before “finish[ing] our audit” indicates she had sufficient authority to speak for her employer.  A reasonable trier of fact could find Russo had the authority necessary to speak for and bind defendants. 

Defendants rely on Mannion v. Campbell Soup Co. (1966) 243 Cal.App.2d 317, 320-321.  That case is distinguishable because the Court of Appeal reviewed a judgment based on evidence, not the pleadings.  (Id. at pp. 318-319.)  The court held there was no “substantia[l] evidence” of a person’s “actual or ostensible authority to bind the company to the contract found by the [trial] court.”  (Id. at p. 321.)  On demurrer, the court cannot make such a finding based solely on the complaint.    

4th Cause of Action: Negligent Misrepresentation

Plaintiff does not allege sufficient facts for negligent misrepresentation.  “To be actionable, a negligent misrepresentation must ordinarily be as to past or existing material facts.  ‘[P]redictions as to future events, or statements as to future action by some third party, are deemed opinions, and not actionable fraud.’ ”  (Tarmann v. State Farm Mut. Auto. Ins. Co. (1991) 2 Cal.App.4th 153, 158.)  There is no cause of action for a “negligent false promise.”  (Id. at p. 159.) 

Plaintiff alleges defendants negligently misrepresented “that they would cover and pay in full the costs for COVID-19 Testing and Services” and that plaintiff’s “cash rate would be honored.”  (Comp., ¶ 131.)  That is a promise, not an actionable statement of past or existing material fact.  It is actionable only under the theory of intentional misrepresentation or “promissory fraud.”  (Lazar v. Superior Court, supra, 12 Cal.4th at p. 638.) 

5th Cause of Action: Unjust Enrichment

Plaintiff does not allege sufficient facts for the fifth cause of action because “California does not recognize a cause of action for unjust enrichment.”  (Hooked Media Group, Inc. v. Apple Inc. (2020) 55 Cal.App.5th 323, 336; accord Everett v. Mountains Recreation & Conservation Authority (2015) 239 Cal.App.4th 541, 553.)

6th Cause of Action: Quantum Meruit

Plaintiff does not allege sufficient facts for this cause of action.  “To recover on a claim for the reasonable value of services under a quantum meruit theory, a plaintiff must establish both that he or she was acting pursuant to either an express or implied request for services from the defendant and that the services rendered were intended to and did benefit the defendant.”  (Ochs v. PacifiCare of California (2004) 115 Cal.App.4th 782, 794.)  Here, plaintiff does not allege sufficient facts to show an express or implied request for services. 

Plaintiff alleges, “Defendants knew and understood that DoctorNow was providing COVID-19 Testing and Services to Defendants’ insureds.  Defendants communicated with DoctorNow regarding submitted claims, paid certain claims for COVID-19 Testing and Services submitted by DoctorNow and were aware of the amounts that DoctorNow charged for COVID-19 Testing and Services.”  (Comp., ¶ 61.)  It further alleges, Defendants, through their conduct, including through the payment of certain claims for COVID-19 Testing and Services submitted by DoctorNow, requested that DoctorNow perform and continue to perform COVID-19 Testing and Services for Defendants’ benefit.”  (¶ 143.)  These conclusory allegations are insufficient.  Paying for services after they are rendered is not the same thing as requesting services.

Common Counts: 7th, 8th, 9th, and 10th Causes of Action

            Plaintiff asserts common count claims for goods and services rendered, money had and received, open book account, and account stated. “ ‘ “A common count is proper whenever the plaintiff claims a sum of money due, either as an indebtedness in a sum certain, or for the reasonable value of services, goods, etc., furnished. It makes no difference in such a case that the proof shows the original transaction to be an express contract, a contract implied in fact, or a quasi-contract.” [Citation.]’ ”  (Utility Audit Co., Inc. v. City of Los Angeles (2003) 112 Cal.App.4th 950, 958.)  Plaintiff fails to state facts sufficient to support a common count because it does not allege facts indicating the parties had an express, implied in fact, or quasi-contract.  (See 1 Witkin, Summary of Cal. Law (11th ed. 2017), Contracts, §§ 102, 103, pp. 145-148 [discussing differences between express contracts, implied in fact contracts, and quasi-contracts].)

11th Cause of Action: Violation of Health & Safety Code § 1342.2

Plaintiff does not allege sufficient facts for this cause of action.  Health & Safety Code section 1342.2 does not permit a private right of action.  “A private party can sue for violation of a statute only where the statute in question allows it.”  (Mayron v. Google LLC (2020) 54 Cal.App.5th 566, 571.)  “[T]here must be a ‘clear, understandable, unmistakable’ indication of intent to allow a private right of action.  It is not enough that the statutory text suggests such a right.”  (Id. at pp. 571-572.) 

Health and Safety Code section 1342.2, subdivision (a)(4) requires “a health service plan” to reimburse health care providers for COVID-19 tests.  Subdivision (g) provides, “The [D]epartment” of Managed Health Care “shall hold health care service plans accountable for timely access to services required under this section and coverage requirements established under federal law, regulations, or guidelines.”  (Id., subd. (g).)  The statute does not expressly provide that health care providers may sue to enforce it.  No provision in section 1342.2 constitutes a clear, understandable, and unmistakable indication of intent to allow a private right of action. 

Plaintiff relies on authority permitting private actions for other provisions of the Knox-Keene Act.  Those cases, however, do not support the proposition that private plaintiffs can sue directly for violations of the Health and Safety Code.  They instead permit claims for quantum meruit for emergency services or unfair competition arising from the Health and Safety Code.  (Blue Cross of California, Inc. v. Superior Court (2009) 180 Cal.App.4th 1237, 1257 [“private plaintiffs can pursue UCL actions based on violations of the Knox–Keene Act”]; Bell v. Blue Cross of California, supra, 131 Cal.App.4th at p. 216 [“Although the Department of Managed Health Care has jurisdiction over the subject matter of section 1371.4 …, its jurisdiction is not exclusive and there is nothing in section 1371.4 or in the Act generally to preclude a private action under the UCL or at common law on a quantum meruit theory”]; Coast Plaza Doctors Hospital v. UHP Healthcare (2002) 105 Cal.App.4th 693, 706 [“conduct in violation of the Knox–Keene Act may be the basis for a cause of action under Business and Professions Code section 17200”].) 

12th Cause of Action: Promissory Estoppel

            Plaintiff alleges sufficient facts for promissory estoppel.  “The elements of a promissory estoppel claim are ‘(1) a promise clear and unambiguous in its terms; (2) reliance by the party to whom the promise is made; (3) [the] reliance must be both reasonable and foreseeable; and (4) the party asserting the estoppel must be injured by his reliance.’ ”  (US Ecology, Inc. v. State of California (2005) 129 Cal.App.4th 887, 901.) 

            Plaintiff alleges sufficient facts at this stage.  It alleges, “Defendants promised insureds and DoctorNow that they would cover and pay in full the costs for COVID-19 Testing and Services.”  (Comp., ¶ 174.)  Plaintiff “relied on Defendants’ promises.”  (Ibid.)  Plaintiff further alleges, “Defendants knew that by their actions and omissions, their payments, and communications, they merely intended for insureds and DoctorNow to rely on those promises, knowing full well that they would later refuse to pay a substantial number of claims that would grow over time.”  (¶ 175.)  Plaintiff alleges it was injured because it provided COVID tests for which it has not been fully paid.  (¶¶ 178, 180.)  Whether plaintiff’s reliance was reasonable or foreseeable is a question of fact that cannot be resolved on demurrer.

13th Cause of Action: Equitable Estoppel

            Equitable estoppel is not a cause of action.  “[E]quitable estoppel ‘acts defensively only.  It operates to prevent one from taking an unfair advantage of another but not to give an unfair advantage of one seeking to invoke the doctrine.’ ”  (Ryder v. Lightstorm Entertainment, Inc. (2016) 246 Cal.App.4th 1064, 1075.)  “[A] stand-alone cause of action for equitable estoppel will not lie as a matter of law.”  (Behnke v. State Farm General Ins. Co. (2011) 196 Cal.App.4th 1443, 1463.) 

14th Cause of Action: Declaratory and Injunctive Relief

Plaintiff does not allege sufficient facts for declaratory relief.  Declaratory relief “operates prospectively” and is not proper “where there is an accrued cause of action for an actual breach of contract or other wrongful act.”  (Baldwin v. Marina City Properties, Inc. (1978) 79 Cal.App.3d 393, 407.)  A claim for declaratory relief does not lie when “ ‘the rights of the complaining party have crystallized into a cause of action for past wrongs’ ” and “a money judgment will fully resolve the dispute.”  (Cardellini v. Casey (1986) 181 Cal.App.3d 389, 396.) 

Plaintiff alleges defendant owes a specific amount of money—down to the penny—for underpaying past claims.  (Comp., ¶ 72.)  Plaintiff further asserts defendants violated a statute that no longer applies because it is now more than “six months after the federal public health emergency expire[d].”  (Health & Saf. Code, § 1342.2, subd. (a)(5).)  The controversy is not prospective.    

As for injunctive relief, plaintiff does not allege sufficient facts to constitute a cause of action because “[i]njunctive relief is a remedy, not a cause of action.”  (Allen v. City of Sacramento (2015) 234 Cal.App.4th 41, 65.) 

Disposition

Defendants Blue Shield of California Life & Health Insurance Company and California Physicians’ Service dba Blue Shield of California’s demurrer to plaintiff’s second, fourth, fifth, sixth, seventh, eighth, ninth, tenth, eleventh, thirteenth, and fourteenth causes of action is sustained with 20 days’ leave to amend.  The demurrer to all other causes of action is overruled.