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Remedies Keyed to Kovacic-Fleischer, 8th
St. Mary’s Medical Center, Inc. v. United Farm Bureau Family Life Insurance Company
Citation:
624 N.E.2d 939 (1993)Facts
On January 23, 1991, Elizabeth Munford was admitted to St. Mary’s Medical Center as an outpatient and listed Farm Bureau as her insurance carrier, assigning her insurance benefits directly to St. Mary’s. Munford incurred medical expenses totaling $3,836.47 during her treatment. St. Mary’s submitted a claim to Farm Bureau on February 5, 1991, and Farm Bureau made partial payment of $3,685.87, which St. Mary’s applied to Munford’s account. After making this payment, Farm Bureau discovered that Munford’s insurance coverage had actually lapsed on December 1, 1990, nearly two months before her admission. Farm Bureau notified St. Mary’s of the mistaken payment and requested a refund on March 29, 1991, and again on May 21, 1991. St. Mary’s had no knowledge of the lapse in coverage until notified by Farm Bureau and made no misrepresentations to induce the payment. St. Mary’s refused to refund the payment, stating it was not their policy to refund payments for medical services already rendered. Farm Bureau filed suit on February 26, 1992, seeking restitution based on mistake of fact.
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