Moore v. Health Care Auth.

CourtWashington Supreme Court
DecidedAugust 21, 2014
Docket89774-3
StatusPublished

This text of Moore v. Health Care Auth. (Moore v. Health Care Auth.) is published on Counsel Stack Legal Research, covering Washington Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Moore v. Health Care Auth., (Wash. 2014).

Opinion

F I I:E IN CLIRIC8 OPPICI "

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IN THE SUPREME COURT OF THE STATE OF WASHINGTON

DOUGLAS L. MOORE, MARY CAMP, ) GAYLORD CASE, and a class of similarly ) situated individuals, ) ) Respondents, ) No. 89774-3 ) v. ) EnBanc ) HEALTH CARE AUTHORITY and ) STATE OF WASHINGTON, ) ) Filed _ _AU_G_2_1_2_0_14__ Petitioners. ) _____________________________)

OWENS, J. - In this class action lawsuit, the trial court found that the State

wrongfully denied health benefits to a number of its part-time employees. We must

now determine how to value the damages suffered by that group of employees when

they were denied health benefits. The State argues that the only damages to the

employees were immediate medical expenses paid by employees during the time they

were denied health benefits. But evidence shows that people denied health care

benefits suffer additional damage. They often avoid going to the doctor for preventive Moore v. Health Care Auth. No. 89774-3

care, and they defer care for medical problems. This results in increased long-term

medical costs and a lower quality of life. Based on this evidence, the trial court

correctly rejected the State's limited definition of damages because it would

significantly understate the damages suffered by the employees. We affirm.

FACTS

In 2006, this class action lawsuit was filed on behalf of part-time employees

who were improperly denied health benefits by the State of Washington. In a series of

partial summary judgment rulings, the trial court ruled that the State violated multiple

statutes when it failed to provide the health benefits. The legislature later codified the

rulings. LAWS OF 2009, ch. 537.

The parties simultaneously moved for summary judgment on the measure of

damages. The State argued that the only damages that it should pay are out-of-pocket

costs paid by class members for medical expenses or substitute health insurance

during the time they were denied health benefits. Furthermore, the State argued that

damages must be established through an individual claims process.

The employees argued that the State's method was inaccurate, contrary to the

evidence, and would lead to a windfall for the wrongdoer. Instead, the employees

proposed three alternative methods of measuring damages. First, the employees

argued that the health benefits were part of the employees' compensation, so the

damages should be based on the employees' lost wages (i.e., the amount the State

2 Moore v. Health Care Auth. No. 89774-3

should have paid to provide health benefits to those employees). Second, the

employees argued that the court could measure damages based on how much money

the State unlawfully retained by failing to provide health benefits to those employees.

Third, the employees argued that the court could measure damages as the amount that

the State would have paid in health care costs for the group of employees had they

been covered. The employees argue that the most accurate measure of this cost is to

use an actuarial method based on the average health care costs for a comparable group

of State employees with health benefits. They presented evidence that this method

would be more accurate than the one proposed by the State because it would take into

account the fact that people postpone medical care when they do not have health

msurance.

The trial court specifically rejected both parts of the State's proposed

approach-limiting damages to out-of-pocket costs and requiring that the damages be

shown through an individual claims process-ruling that it was "wrong as a matter of

common sense, public policy and general knowledge." Clerk's Papers (CP) at 591.

The court generally agreed with the employees that the failure to pay benefits was a

failure to pay wages and, alternatively, that the State may owe restitution because it

received a windfall when it failed to provide these benefits. The trial court

nonetheless concluded that issues of fact remained, including how many members of

3 Moore v. Health Care Auth. No. 89774-3

the class would likely have opted out of coverage altogether, so it denied both motions

for summary judgment.

The State moved for discretionary review of the trial court's order, which the

Court of Appeals commissioner granted. The employees moved to transfer review to

this court pursuant to RAP 4.4, which the acting commissioner granted.

ISSUES

1. Did the trial court err when it rejected the State's proposed method of

calculating damages, which took into account only out-of-pocket expenses assessed

through an individual claims process?

2. Did the trial court err when it expressed support for the employees'

proposed methods of calculating damages, which were equivalent to the amount the

State should have paid for the health benefits wrongfully denied to the employees?

STANDARD OF REVIEW

The parties dispute the standard of review. The employees characterize the

issue as the judge "choosing one of several lawful measures of damages," which

should be reviewed for abuse of discretion. Br. of Pl. Class/Resp 'ts at 12 (citing In re

Marriage ofFarmer, 172 Wn.2d 616, 631-32, 259 P.3d 256 (2011)). The State

characterizes the issue as the determination of the measure of damages, which is a

question of law and thus reviewed de novo. Br. of Appellants at 14 n.27 (citing

Shoemake v. Ferrer, 168 Wn.2d 193, 198, 225 P.3d 990 (2010)). There was a similar

4 Moore v. Health Care Auth. No. 89774-3

dispute over the standard of review in Farmer, and we concluded that "[i]n a sense

both parties are correct." 172 Wn.2d at 624. The trial judge's ultimate choice of

remedy is reviewed for abuse of discretion, but "a trial court necessarily abuses its

discretion if it awards damages based upon an improper method of measuring

damages." !d. at 625.

Thus, we essentially have two questions with two different standards. First, we

determine as a matter of law whether the measure of damages proposed by the State is

the only proper measure. If so, we must reverse the trial court's decision as a matter

of law. If multiple measures of damages are allowed by law, then we review the

judge's choice of measure for abuse of discretion.

ANALYSIS

1. Immediate Out-of-Pocket Costs Is Not the Only Permissible Measure of Damages

The State argues that the only proper measure of damages for the wrongfully

denied health benefits is the out-of-pocket costs incurred by employees for the

payment of covered medical expenses or the purchase of substitute health insurance.

We disagree. The State's measure relies on the assumption that the only damages

suffered by those denied health benefits are out-of-pocket expenses incurred during

the time period they were denied benefits-an assumption that is contradicted by both

common sense and the evidence in the record. The State also argues that its proposed

measure is the only one allowed by law based on non-health-insurance case law in

5 Moore v. Health Care Auth. No. 89774-3

Washington and certain out-of-state cases. Because the reasoning in those cases does

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