Sarun

Tony Sarun was uninsured when he received emergency health care services from a hospital owned and operated by Dignity Health. Upon admission Sarun signed an agreement to pay the hospital’s “full charges, unless other discounts apply.” The agreement explained uninsured patients might qualify for government aid programs or financial assistance from Dignity. After receiving an invoice for $23,487.90, which reflected a $7,871 “uninsured discount,” and without applying for any other discount or financial assistance, Sarun filed a putative class action complaint asserting claims including unfair and/or deceptive business practices under Business and Professions Code section 17200 et seq. (UCL) and violation of the Consumers Legal Remedies Act (CLRA) (Civ. Code, § 1750 et seq.). The complaint alleged Dignity had failed to disclose uninsured patients would be required to pay several times more than other patients receiving the same services, the charges set forth on the invoice were not readily available or discemable from the agreement, and the invoiced charges exceeded the reasonable value of the services.

The trial court sustained Dignity’s demurrer to Sarun’s second amended…