North American Consultants, Inc. v. MacLennan, D.A., D.C., Individually and as Representative of All Persons Similarly Situated

CourtCourt of Appeals of Texas
DecidedDecember 7, 2000
Docket13-00-00289-CV
StatusPublished

This text of North American Consultants, Inc. v. MacLennan, D.A., D.C., Individually and as Representative of All Persons Similarly Situated (North American Consultants, Inc. v. MacLennan, D.A., D.C., Individually and as Representative of All Persons Similarly Situated) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
North American Consultants, Inc. v. MacLennan, D.A., D.C., Individually and as Representative of All Persons Similarly Situated, (Tex. Ct. App. 2000).

Opinion

NUMBER 13-00-289-CV

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI

____________________________________________________________________

NORTH AMERICAN

CONSULTANTS, INC., Appellant,

v.

D.A. MACLENNAN, D.C., INDIVIDUALLY AND AS

CLASS REPRESENTATIVE OF ALL PERSONS SIMILARLY SITUATED, Appellee.

____________________________________________________________________

On appeal from the 130th District Court of Matagorda County, Texas.

____________________________________________________________________

O P I N I O N

Before Justices Hinojosa, Yañez, and Chavez

Opinion by Justice Yañez

This is an interlocutory appeal from an order certifying a class of individual chiropractors alleging claims of defamation and tortious interference against appellant, North American Consultants, Inc. ("NAC"), a company that reviews medical and billing records for insurance carriers. Because the trial court's certification order does not meet the requirements recently articulated by the Texas Supreme Court, we reverse and remand to the trial court. See Southwestern Ref. Co., Inc. v. Bernal, 22 S.W.3d 425, 435 (Tex. 2000).(1)

Appellee, D. A. MacLennan ("MacLennan"), is a chiropractor who treated a patient, Michael Garcia, and submitted a bill for chiropractic services to Farmers Insurance Company ("Farmers") requesting payment. NAC reviews patients' records and provides opinions in the form of "retrospective reviews" concerning bills submitted by medical service providers for payment. MacLennan alleges that NAC's opinions to Farmers regarding the "reasonableness" of certain charges and the "medical necessity" of certain chiropractic treatments constitutes defamation and tortious interference in his personal service contract with his patient.

Background

Garcia received chiropractic treatment from MacLennan in connection with injuries he received in an automobile accident. Garcia's attorney, Lynn Grebe, forwarded Garcia's medical bills, including those submitted by MacLennan, to Farmers for payment under an automobile insurance policy. Following a review, Farmers forwarded the bills to NAC for a retrospective review concerning the reasonableness of the charges and the medical necessity of the treatment provided. A chiropractor retained by NAC reviewed the bills and issued a report to Farmers, dated January 22, 1998, stating that of the $2,410 in charges submitted by MacLennan, $1,275 was for treatment which was "not medically necessary." Farmers sent the report to Grebe, who, in turn, forwarded it to MacLennan for a response. MacLennan provided additional information regarding treatment, and asked for reconsideration. NAC issued a second report, dated February 20, 1998, which, like the first report, characterized $1,275 as for treatment "not medically necessary." The opinions in the February 20, 1998 report form the basis of MacLennan's claims for defamation and tortious interference.(2)

MacLennan filed a class action lawsuit on behalf of all similarly situated chiropractors, alleging that NAC's reports constitute defamation.(3) After NAC moved for summary judgment, MacLennan filed an amended petition, adding a cause of action for tortious interference in the doctor-patient relationship. The trial court denied NAC's motion for summary judgment.

MacLennan submitted a motion for class certification, and without a hearing, the trial court issued a certification order on April 14, 2000, certifying a class of "[a]ll chiropractors whose treatment of patients has been the subject of a report by defendant, North American Consultants, Inc., to any person other than the chiropractor." This interlocutory appeal followed.

By three issues, NAC contends: (1) the trial court abused its discretion by certifying a class of plaintiffs asserting individual defamation and tortious interference claims; (2) MacLennan failed to show that the numerosity, typicality, commonality, adequacy, and predominance requirements of Texas Rule of Civil Procedure 42 are satisfied; and (3) the trial court erred by improperly certifying a broad class, because the class is defined by the ultimate issue of liability; is not limited to the applicable one-year limitations period; is unlimited in scope; and includes instances in which reviews are allowed, or even required, by Texas or federal law. MacLennan argues that the common issue, i.e., whether a statement to a third party, to the effect that a chiropractor gives a patient medically unnecessary treatment, is defamatory, predominates over any individual issues of class members. He also argues that NAC waived its argument that individual issues predominate because it refused discovery concerning the nature of the individual issues.

Standard of Review

An appellate court reviews a trial court's determination that a case should be certified as a class action using an abuse of discretion standard. Monsanto Co. v. Davis, 25 S.W.3d 773, 781 (Tex. App.--Waco 2000, no pet.); Health & Tennis Corp. of Am. v. Jackson, 928 S.W.2d 583, 587 (Tex. App.--San Antonio 1996, writ dism'd w.o.j.). The trial court abuses its discretion when it does not properly apply the law to the undisputed facts, when it acts arbitrarily or unreasonably, or when its ruling is based on factual assertions unsupported by the record. Monsanto, 25 S.W.3d at 781. In reviewing the trial court's ruling on certification, an appellate court is required to view the evidence in a light most favorable to the trial court's action and indulge every presumption in favor of the trial court's ruling. See Spera v. Fleming, Hovenkamp, & Grayson

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Related

Southwestern Refining Co., Inc. v. Bernal
22 S.W.3d 425 (Texas Supreme Court, 2000)
Monsanto Co. v. Davis
25 S.W.3d 773 (Court of Appeals of Texas, 2000)
Nissan Motor Co., Ltd. v. Fry
27 S.W.3d 573 (Court of Appeals of Texas, 2000)
Spera v. Fleming, Hovenkamp & Grayson, P.C.
4 S.W.3d 805 (Court of Appeals of Texas, 1999)
Life Insurance Co. of Southwest v. Brister
722 S.W.2d 764 (Court of Appeals of Texas, 1986)
Rainbow Group, Ltd. v. Johnson
990 S.W.2d 351 (Court of Appeals of Texas, 1999)
Health & Tennis Corp. of America v. Jackson
928 S.W.2d 583 (Court of Appeals of Texas, 1996)

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North American Consultants, Inc. v. MacLennan, D.A., D.C., Individually and as Representative of All Persons Similarly Situated, Counsel Stack Legal Research, https://law.counselstack.com/opinion/north-american-consultants-inc-v-maclennan-da-dc-i-texapp-2000.