Justia Antitrust & Trade Regulation Opinion SummariesArticles Posted in Iowa Supreme Court
Chicoine v. Wellmark, Inc.
In this case, three chiropractors and their respective business entities sued Wellmark, Iowa’s largest health insurer and claims administrator, alleging that the company violated Iowa antitrust laws through its Administrative Service Agreements with over 400 Iowa employers who self-fund healthcare benefits for their employees. The chiropractors argued that without these agreements, the self-funded employers would compete independently for chiropractic services, resulting in higher profits for chiropractors. The chiropractors filed a motion to certify a class of approximately 1,300 Iowa chiropractors. However, the Supreme Court of Iowa affirmed the district court's decision to deny class certification, concluding that the chiropractors failed to meet the predominance requirement for class certification as they could not prove the threshold issue of antitrust injury on a classwide basis. The court found that proving whether individual chiropractors would be better or worse off without Wellmark’s agreements would require numerous mini-trials, and thus, individual questions predominated over common questions. Additionally, the court applied the doctrine of judicial estoppel to prevent the chiropractors from belatedly reviving a different liability theory that they had previously abandoned to avoid a motion to dismiss. View "Chicoine v. Wellmark, Inc." on Justia Law
Poller v. Okoboji Classic Cars, LLC
The Supreme Court affirmed in part and reversed in part the judgment of the district court concluding that Plaintiffs were not entitled to relief on their contract claim and that Defendant was entitled to a verdict on its counterclaim for breach of contract, holding that judgment was improperly granted on Defendant's counterclaim.Plaintiffs, the owners of a 1931 Chevy, brought this lawsuit against Defendant, a company in the business of restoration of antique vehicles, arguing that Defendant violated certain provisions of the Motor Vehicle Service Trade Practices Act (MVSTPA), Iowa Code chapter 537B and breached its contract with Plaintiffs. Defendant filed a counterclaim alleging breach of contract. The district court concluded that there were no violations of the MVSTPA, that Plaintiffs were not entitled to relief on their contract claim, and that Defendant was entitled to damages on its counterclaim. The Supreme Court reversed the judgment in favor of Defendant on the counterclaim, holding that Defendant violated several provisions of Iowa Code chapter 537B and therefore may not seek to enforce the terms of a contract that was unlawfully formed, but Plaintiffs did not establish actual damages arising from the alleged damages. View "Poller v. Okoboji Classic Cars, LLC" on Justia Law