Doster v. Pomona Valley Hospital Medcial Center CA
Plaintiff Terri Doster believes that the defendant hospital charged her too much for emergency room services. She seeks to represent a class of similarly situated uninsured emergency room patients in a single cause of action for declaratory relief. In contrast to a cause of action for breach of contract, declaratory relief does not require proving damages.
Doster eschews class certification of any cause of action requiring proof of damages because damages for overbilling of emergency room services requires individual determinations and is fatal to class action status. (Hale v. Sharp Heathcare (2014) 232 Cal.App.4th 50, 53 [affirming decertification of uninsured patient class because of individual issues related to damages].) Doster sought class certification solely to obtain a declaration that the hospital may charge only the “reasonable value” of its emergency room services.
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