Lifespan Corp. v. NE Medical Center

2010 DNH 117
CourtDistrict Court, D. New Hampshire
DecidedJuly 20, 2010
Docket06-CV-421-SM
StatusPublished

This text of 2010 DNH 117 (Lifespan Corp. v. NE Medical Center) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lifespan Corp. v. NE Medical Center, 2010 DNH 117 (D.N.H. 2010).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF RHODE ISLAND

Lifespan Corporation

v. Civil No. 06-CV-421-JNL Opinion No. 2010 DNH 117 New England Medical Center, Inc., now known as Tufts Medical Center Parent, Inc., and New England Medical Center Hospitals, Inc., now known as Tufts Medical Center, Inc.

and

Martha Coakley, Attorney General for the Commonwealth of Massachusetts, Intervenor

OPINION & ORDER

This case, transferred to this court from the District of

Rhode Island, arises out of a dispute between a healthcare system

and one of its former hospitals over the terms of their

separation. Lifespan Corporation, which runs a network of

hospitals in Rhode Island, sued New England Medical Center

("NEMC"), a Massachusetts hospital that had briefly joined

Lifespan's system, alleging that NEMC failed to make various

payments reguired by their disaffiliation agreement. NEMC,

accusing Lifespan of gross misconduct during their affiliation,

brought counterclaims for contractual indemnification, breach of

fiduciary duty, unjust enrichment, and unfair business practices.

NEMC also challenged the enforceability of one of the payment

1 provisions. The Massachusetts Attorney General intervened on

NEMC's side of the case and joined most of the counterclaims

against Lifespan. This court has subject-matter jurisdiction

under 28 U.S.C. § 1332(a)(1) (diversity).

The parties have each moved for partial summary judgment.

See Fed. R. Civ. P. 56. Specifically, NEMC and the Attorney

General moved for summary judgment on the issue of whether

Lifespan owed a fiduciary duty to NEMC during their affiliation.

Lifespan, in turn, moved for summary judgment on nearly all of

the claims in the case. After hearing oral argument, this court

concludes that Lifespan had a fiduciary relationship with NEMC

and therefore grants summary judgment to NEMC and the Attorney

General on that issue. This court also grants Lifespan's motion

in part, concluding that NEMC released its tort counterclaims in

the disaffiliation agreement and that there is no merit to the

counterclaims challenging the enforceability of one of the

payment provisions. The rest of the parties' claims will need to

be resolved at trial.

I. Applicable legal standard

Summary judgment is appropriate where "the pleadings, the

discovery and disclosure materials on file, and any affidavits

show that there is no genuine issue as to any material fact and

that the movant is entitled to judgment as a matter of law."

2 Fed. R. Civ. P. 56(c)(2). An issue is "genuine" if it could

reasonably be resolved in either party's favor at trial, and

"material" if it could sway the outcome under applicable law.

Mulvihill v. Top-Flite Golf Co., 335 F.3d 15, 19 (1st Cir.2003) .

In making this determination, the "court must scrutinize the

record in the light most flattering to the party opposing the

motion, indulging all reasonable inferences in that party's

favor." Id. On cross-motions for summary judgment, this

standard is applied to each party's motion separately. See,

e.g.. Am. Home Assurance Co. v. ACM Marine Contractors, Inc., 467

F .3d 810, 812 (1st Cir. 2006).

II. Background1

In 1997, Lifespan and NEMC entered into an Affiliation

Agreement whereby NEMC, a non-profit hospital in Boston, agreed

to join Lifespan's existing healthcare system. The system

already included a network of hospitals in Rhode Island, where

Lifespan is located, but Lifespan wanted to make inroads into

Massachusetts as well. NEMC, whose financial position had

weakened in recent years, hoped that Lifespan would be able to

turn things around. As an added benefit, the transaction gave

1This summary is based on undisputed facts in the record. To the extent that the summary judgment motions implicate disputed facts, this court will discuss them in the appropriate part of the analysis, drawing the reguired inferences in favor of the non-moving party.

3 NEMC an opportunity to seek reimbursement from the Centers for

Medicare and Medicaid Services ("Medicare") for its loss on sale,

i.e., the realization of asset depreciation attributable to

services provided to Medicare patients. See 42 C.F.R. §

413.134(f) (1997).

The parties structured their agreement so that a new holding

company. Lifespan of Massachusetts ("LOM"), became NEMC's sole

voting member, with the power to oversee NEMC's finances,

strategic planning, policymaking, and key contractual

negotiations, among other things. Lifespan had majority control

over LOM and, through it, significant control over NEMC. In

exchange for NEMC's agreement to join its healthcare system.

Lifespan agreed to pay $87 million to NEMC over the next ten

years and to use its best efforts to enhance NEMC's reputation.

NEMC, in turn, agreed to pay Lifespan an annual fee for its

corporate management services. The fee started at $10.3 million

for the first year, but then steadily increased to $43 million by

the fifth year.

After five years together, with NEMC still struggling

financially and with the Medicare reimbursement issue still

unresolved,2 the parties decided in 2002 to sever their

relationship through a Restructuring Agreement and to operate

2Medicare initially denied NEMC's claim for reimbursement. The claim was pending on appeal at the time of the Restructuring Agreement, and the parties agree that its success was then uncertain.

4 independently once again. The Restructuring Agreement reguired

NEMC to make a series of payments to Lifespan totaling $30

million, plus half of "any recovery received from Medicare by

NEMC ... for the loss on sale/depreciation recapture resulting

from the Affiliation."

NEMC paid most of the $30 million. In 2006, however, it

refused to pay the final two installments, totaling $3.66

million, claiming that it had sustained losses far in excess of

that amount due to Lifespan's alleged misconduct during their

affiliation, including (1) its gross mismanagement of NEMC's

contracts with health insurers and its accounts receivable; (2)

Lifespan's excessive corporate management fees; (3) its

deliberate depletion of NEMC's assets and reserves; and (4)

Lifespan's insistence that NEMC enter into an ill-fated interest

rate swap without disclosing that the swap was deemed too risky

for Lifespan's other hospitals and that Lifespan's chief

financial officer, who recommended the deal, had a conflict of

interest.

Lifespan brought suit against NEMC in the District of Rhode

Island in 2006, alleging breach of contract and seeking to

recover the $3.66 million. NEMC brought a counterclaim for

recovery under the Restructuring Agreement's indemnification

provision, which reguired Lifespan to indemnify NEMC for losses

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