Harper v. Cook County & Health Care Service Corp.

2021 IL App (1st) 200332-U
CourtAppellate Court of Illinois
DecidedMarch 10, 2021
Docket1-20-0332
StatusUnpublished

This text of 2021 IL App (1st) 200332-U (Harper v. Cook County & Health Care Service Corp.) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Harper v. Cook County & Health Care Service Corp., 2021 IL App (1st) 200332-U (Ill. Ct. App. 2021).

Opinion

2021 IL App (1st) 200332-U

THIRD DIVISION March 10, 2021 1-20-0332

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1).

IN THE APPELLATE COURT OF ILLINOIS FIRST JUDICIAL DISTRICT

KATHLEEN HARPER, ) Appeal from the ) Circuit Court of Plaintiff-Appellant, ) Cook County. ) v. ) No. 19 L 8471 ) COOK COUNTY and HEALTH CARE SERVICE ) Honorable CORPORATION, ) Daniel J. Kubasiak, ) Judge Presiding. Defendants-Appellees. )

PRESIDING JUSTICE HOWSE delivered the judgment of the court. Justices McBride and Burke concurred in the judgment.

ORDER

¶1 Held: We affirm the judgment of the trial court dismissing the plaintiff’s complaint with

prejudice; plaintiff lacked standing to pursue a taxpayer action under the circumstances

presented.

¶2 Kathleen Harper sued Cook County and Health Care Service Corporation alleging their

misuse of public money in the administration of the county’s employee healthcare program.

Harper claimed her right to bring a taxpayer action to void the unauthorized service agreements

between the county and HCSC. 1-20-0332

¶3 The trial court dismissed Harper’s complaint with prejudice on the grounds she lacked

standing to pursue a taxpayer action and did not allege sufficient facts to support the assertion

that the service agreements are unauthorized and therefore void ab initio. Harper contends the

trial court erred in dismissing her complaint with prejudice because: (a) she has standing to sue

in her capacity as a taxpayer; (b) the county entered a contract that does not comply with state

law; and (c) she and her fellow taxpayers are liable to replenish the county’s coffers. For the

following reasons, we affirm the judgment of the trial court.

¶4 Background

¶5 In 2019, Harper filed a complaint against Cook County and HCSC to void their alleged

unauthorized service agreements and for restitution. HCSC, a mutual reserve company doing

business as Blue Cross Blue Shield of Illinois, is the third-party administrator of the county’s

self-funded employee healthcare plans. The service agreement between HCSC and the county

was approved by the Board of Cook County Commissioners and the term of the agreement began

on December 1, 2015, and continued until November 30, 2018, unless terminated earlier. The

maximum amount to be paid by the county under the agreement, in the initial three-year term,

was $884,195,500.00 unless there was a written amendment.

¶6 According to her complaint, when a county employee receives medical treatment under

the county healthcare plan, HCSC pays healthcare providers for their services on behalf of the

county. HCSC then presents a bill to the county for the services and the county reimburses

HCSC for the amount of the bill plus a small administrative fee. However, Harper alleged that

HCSC receives a further discount from service providers, which increases the income of HCSC.

She alleged the service agreements allow HCSC to retain an undisclosed amount of

“compensation” pursuant to separate financial “arrangements” between HCSC and the healthcare

2 1-20-0332

providers. And because the terms of those separate arrangements are not disclosed to the county

or its taxpayers, “the money taken from the public funds of Cook County [and] retained by

HCSC for its services under its agreements with Cook County as well as the method/record of

the calculation and receipt of the total compensation is not disclosed to Cook County or to the

taxpayer/public.”

¶7 Harper alleged the service agreements are in derogation of state law and consequently

void ab initio because they allow HCSC to receive additional, undisclosed compensation from

healthcare providers. She alleged that article VIII, section I of the Illinois Constitution (general

provisions regarding public funds), the Local Records Act (50 ILCS 205/3 (West 2020) (defining

“public records”)), the Counties Code (55 ILCS 5/6-24001 et seq. (West 2020)), and the

common law of Illinois require that all agreements between a government unit and a private

vendor for the expenditure of public funds must be approved by a prior appropriation of a

specific amount of money and maintained as public records. She further alleged the county

exceeded its statutory authority in entering the service agreements “because they fail to disclose

the details and amount of that [additional] compensation in the public record.”

¶8 Harper claimed standing to bring a taxpayer action because she and her fellow taxpayers

pay the cost of the county’s self-funded employee healthcare programs. She sought restitution

from HCSC based on claims for unjust enrichment, assumpsit, and an accounting.

¶9 Attached to her complaint was the latest service agreement between the county and

HCSC, which provided it was authorized by the Board of Commissioners in 2015:

“This Agreement is made and entered into by and between the County of

Cook, a public body corporate of the State of Illinois, on behalf of Office of the

Chief Procurement Officer hereinafter referred to as ‘County’ and Blue Cross and

3 1-20-0332

Blue Shield of Illinois (“BCBSIL”), a division of Health Care Service

Corporation, *** pursuant to authorization by the Cook County Board of

Commissioners on October 28, 2015, as evidenced by Board Authorization letter

attached hereto as Exhibit 11.”

¶ 10 In count I for unjust enrichment, Harper alleged the service agreements are void ab initio

because “of the law prohibiting a private vendor and a unit of local government from entering

into any agreement that does not limit the payments to be made to the vendor to those amounts

fully disclosed.” She claimed the county breached its duty to comply with state law “prohibiting

a public entity or official acting on behalf of such an entity from entering into such an

agreement.” And HCSC has a similar duty to comply. She alleged that taxpayers are obliged to

replenish the public funds for the loss of the payments made to HCSC. In counts II (assumpsit)

and III (accounting), she alleged the county “paid sums to HCSC that HCSC was not legally

entitled to receive,” and “there is no record of the actual amount paid to HCSC for its alleged

services.”

¶ 11 HCSC filed a combined motion to dismiss Harper’s complaint pursuant to section 2-

619.1 of the Code of Civil Procedure. 735 ILCS 5/2-619.1 (West 2020). HCSC sought dismissal

under section 2-615 arguing Harper failed to plead a legally cognizable taxpayer action. 735

ILCS 5/2-615 (West 2020). HCSC sought dismissal under section 2-619(a)(9) arguing that

Harper has no standing to pursue a taxpayer action, and where the county is the real party in

interest, only the State’s Attorney is authorized to assert such claims on behalf of the county. 735

ILCS 5/2-619(a)(9) (West 2020). HCSC attached a copy of its service agreement with the

county. Exhibit 11, entitled “Board Authorization,” details the specific amount of money

proposed for the contract and the Board’s request for authorization to enter the contract.

4 1-20-0332

¶ 12 HCSC noted that the county is well aware of the discount it receives from providers and

this discount was contemplated in the contract.

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Bluebook (online)
2021 IL App (1st) 200332-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harper-v-cook-county-health-care-service-corp-illappct-2021.