Crabill v. LCA-Vision Inc

CourtDistrict Court, S.D. Ohio
DecidedMarch 31, 2025
Docket1:23-cv-00280
StatusUnknown

This text of Crabill v. LCA-Vision Inc (Crabill v. LCA-Vision Inc) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Crabill v. LCA-Vision Inc, (S.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

MAREN CRABILL, individually and on : Case No. 1:23-cv-280 behalf of all others similarly situated, : : Judge Timothy S. Black Plaintiff, : : vs. : : LCA-VISION, a corporation, also d/b/a : LASIKPLUS, also d/b/a JOFFE : MEDICENTER, : : Defendant. :

ORDER GRANTING MOTION TO DISMISS FOR LACK OF ARTICLE III STANDING

This civil action is before the Court on Defendant’s motion to dismiss and to strike the class allegations (Doc. 11), the parties’ responsive memoranda (Docs. 14, 17), and Plaintiff’s Notice of Supplemental Authority (Doc. 18). On May 12, 2023, Plaintiff Maren Crabill (“Plaintiff”) brought this civil class action against Defendant LCA-Vision, Inc. d/b/a LasikPlus and Joffe Medicenter (“Defendant” or “LCA”), alleging the following claims: violation of the Connecticut Unfair Trade Practices Act (“CUTPA”), Conn. Gen. Stat. § 42-110(a), et seq.; unjust enrichment; fraud; fraudulent omission; and breach of express warranty. (Doc. 1). On September 10, 2023, Plaintiff filed a First Amended Complaint, which filing provided additional information regarding the parties and allegations but did not amend the claims. (Doc. 10). I. BACKGROUND Defendant is an Ohio corporation that operates vision/surgery centers in numerous states under the names LasikPlus or Joffe MediCenter. (Doc. 10 at ¶ 5). Specifically,

Defendant provides management and administrative services for all LasikPlus centers and Joffe MediCenters. (Id. at ¶ 6). These services include, inter alia, marketing and advertising, billing, accounting, patient scheduling, and running the patient call center. (Id.) LasikPlus and Joffe MediCenters (collectively, the “surgical centers”) offer

services including eye examinations, consultations, and LASIK surgery. (Id. at ¶ 7). The surgical centers employ optometrists, technicians, and other support personnel, as well as contracting with affiliated independent medical professionals—ophthalmological surgeons—who perform LASIK surgery. (Id.) LASIK surgery is a procedure that can correct myopia (nearsightedness), hyperopia (farsightedness), and astigmatism (having an

oval-shaped cornea, resulting in visual distortion), thereby restoring a patient’s eyesight to near 20/20 vision as measured on the Snellen eye chart. (Id.) The surgical centers typically use two types of lasers for surgery, a VISX excimer laser (“Traditional VISX Laser”) and a Wavelight excimer laser (“Wavelight Laser”). (Id. at ¶ 8). The Traditional VISX Laser uses an older “broad beam” laser technology,

whereas the Wavelight Laser is a more technologically-advanced “flying spot” laser, allowing it to produce faster and more precise corneal corrections. (Id.) Defendant claims the Wavelight Laser can more effectively treat patients with higher prescriptions (worse eyesight) and larger pupils, and is less likely to result in post-operative complications such as reduced night vision and seeing halos around lights. (Id.) Eligibility for vision correction surgery depends upon various factors, including a

patient’s prescription level, the thickness of the cornea, the size of the pupil, and the stability of the prescription. (Id. at ¶ 9). Defendant sets surgery price guidelines and parameters, including which prescriptions are eligible for certain pricing, but generally leave decisions as to a patient’s eligibility for LASIK surgery, and the appropriate type of surgery and laser, to the judgment of its surgeons and optometrists. (Id.) Some of the

surgeons who contract with Defendant limit the use of the Traditional VISX Laser to patients who are nearsighted with relatively low prescriptions. (Id.) Others use the Traditional VISX Laser to correct the eyesight of patients with a wide array of prescriptions, including those who are farsighted and those with a high degree of correction. (Id.) Defendant estimates the retail value of its LASIK surgery is $4,000, or

$2,000 per eye. (Id.) Starting in or around 2015, Defendant began advertising a limited-time promotional offer for LASIK surgery at a reduced cost. (Id. at ¶¶ 10-11). These advertisements were disseminated through television, radio, print, shopping flyers, email, and the Internet. (Id. at ¶ 10).

Specifically, Defendant advertised LASIK surgery available to patients for as little as $250 (LasikPlus) or $295 (Joffe MediCenters). (Id.) Additionally, the advertisements all noted that restrictions applied to the offer, but did not specify adequately (if at all) the nature of those restrictions nor provide sufficient information regarding eligibility requirements. (Id.) Instead, the advertisements typically instructed interested consumers to call the surgical centers or to visit their website to schedule a free consultation and/or receive further details about the promotional offer. (Id. at ¶¶ 11-22).1

As it would turn out, the eligibility requirements for Defendant’s lowest advertised prices of $250 or $295 were fairly restrictive. That is, to qualify for the lowest price, the patient could not be fair-sighted nor have eyesight worse than -1.00. (Id. at ¶ 29). In other words, the promotional price was essentially available only to those who were near- sighted and had “near-normal vision.” (Id.) Additionally, the promotional price only

applied to surgeries done using the Traditional VISX Laser. (Id. at ¶ 31). And although the surgical centers’ websites did contain these restrictions and eligibility disclosures, the information was contained in the fine print at the bottom of the page. (Id. at 19-22). Additionally, while Defendant’s call centers initially provided eligibility information to consumers who inquired by phone, Defendant changed its call center policies after

finding that consumers who learned the promotional-price limitations were less likely to schedule a free consultation. (Id. at ¶ 27). As a result, Defendant instructed call center employees to respond to any inquiries regarding eligibility by telling the caller that only the doctor, after a consultation, can determine whether a consumer is eligible. (Id.) As to the free consultations, patients typically spent anywhere from 90 minutes to

two hours at the surgery centers and underwent multiple types of eye examinations before

1 Plaintiff’s Amended Complaint contains the full script of Defendant’s radio and television advertisements, as well as the content and accompanying screenshots of Defendant’s printed advertisements. (Doc. 10 at ¶¶ 11-22). The Court incorporates this information by reference. meeting with the optometrist to learn whether or not they qualified for the promotional pricing. (Id. at ¶¶ 28-29). Per company policy, Defendant’s staff did not advise patients as to eligibility for the promotional price before the end of the consultation, even if it

were evident at an earlier stage that the patient would not qualify. (Id.) Ultimately, only 6.45% of patients who visited Defendant’s surgery centers for the free consultation qualified for the promotional price for both eyes. (Id. at ¶ 32). Patients who qualified for the promotion in only one eye (due to having worse eyesight in one eye than the other) were offered the promotional price for the qualifying eye and then quoted

a higher price in the range of $695 to $2,295 for the other eye. (Id.) Moreover, even for qualifying patients, Defendant’s staff would sometimes discourage undergoing the procedure using the Traditional VISX Laser and promote the (more expensive) Wavelight Laser as a safer and more effective option, thereby talking the patient out of the promotional offer. (Id. at ¶¶ 33-34).

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Crabill v. LCA-Vision Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/crabill-v-lca-vision-inc-ohsd-2025.