The Tennessee Supreme Court today held that the state’s collateral estoppel doctrine prevents a plaintiff from relitigating the issue of class certification in a refiled case. Collateral estoppel, sometimes referred to as issue preclusion, is a legal doctrine which bars the same parties from relitigating legal or factual issues that were raised and determined in an earlier proceeding.
In Emergency Medical Care Facilities, P.C. v. BlueCross BlueShield of Tennessee, Inc., et al., the plaintiffs alleged the same claims against the same defendants on behalf of the same class where class certification was denied in the prior case and affirmed on appeal.
This case involved the application of TennCare’s $50 cap on reimbursement payments for non-emergency services performed in emergency rooms. In 2014, Plaintiff Emergency Care Medical Facilities, P.C., a professional corporation of physicians and other healthcare providers, sued BlueCross BlueShield of Tennessee, Inc. and its subsidiary, Volunteer State Health Plan, Inc., alleging the Defendants’ application of the cap breached various contracts and moved to certify the case as a class action. The trial court’s denial of the class certification motion was affirmed by the Tennessee Court of Appeals, and the case was remanded to the trial court. After remand, Plaintiff voluntarily dismissed its case and then refiled it in 2018, again seeking to certify the case as a class action. Since the prior order was final and the issues were identical, the Tennessee Supreme Court held that the Plaintiff in this case was collaterally estopped from relitigating the issue of class certification.
To read the unanimous opinion in Emergency Medical Care Facilities, P.C. v. BlueCross BlueShield of Tennessee, Inc., et al., authored by Justice Dwight E. Tarwater, visit the opinions section of TNcourts.gov.