St. Vincent Medical Center v. Mega Life and Health Insurance

MEMORANDUM

Plaintiff-Appellant St. Vincent Medical Center (“St. Vincent”) appeals from the district court’s grant of summary judgment in favor of The MEGA Life and Health Insurance Company (“MEGA Life”). In the district court, St. Vincent unsuccessfully argued that MEGA Life breached a contract with it and, in the alternative, that MEGA Life was estopped from failing to pay for care received by two of its insureds.

The general rule in California is that “only a signatory to a contract may be liable for any breach.” Clemens v. Am. Warranty Corp., 193 Cal.App.3d 444, 452 , 238 Cal.Rptr. 339 (1987); see also Jones v. AIG Risk Mgmt., Inc., 726 F.Supp.2d 1049, 1055 (N.D.Cal.2010) (dismissing, under California law, claim for breach of contract against defendant not party to the contract); Tri-Continent Int’l Corp. v. Paris Sav. & Loan Assoc., 12 Cal.App.4th 1354, 1359 , 16 Cal.Rptr.2d 508 (1993) (explaining that “[plaintiff] cannot assert a claim for breach of contract against one who is not a party to the contract”). The parties do not dispute that there is no written agreement between St. Vincent and MEGA Life.

St. Vincent seeks to avoid the general rule by arguing that a series of…