Pomona Valley Hospital v. Kaiser Foundation Health (Feb. 27, 2026, A168669) ___ Cal.App.5th ___ [2026 WL 554484], ordered published March 13, 2026
Pomona Valley Hospital sued Kaiser Foundation Health Plan in quantum meruit to recover the unreimbursed reasonable value of emergency services Pomona Valley provided to Kaiser Health Plan members. Pomona Valley had provided emergency medical services to Kaiser Health Plan members under a contract that set the reimbursement rates for those services. After Kaiser Health Plan terminated the contract, it began paying Pomona Valley a lower amount that Kaiser Health Plan determined was the reasonable value for those services. Pomona Valley sued to recover the higher unreimbursed fair market value for its emergency care. A jury ruled in Pomona Valley’s favor, but the trial court conditionally granted Kaiser Health Plan’s motion for a new trial, ruling it had erred by admitting the expired contract as evidence of the services’ value. Pomona Valley accepted a remitted judgment in lieu of a new trial. Kaiser Health Plan then appealed, and Pomona Valley cross-appealed.
The Court of Appeal reversed the order granting a new trial and vacated the amended judgment, holding the trial court correctly denied Kaiser Health Plan’s motion in limine to exclude evidence of the expired reimbursement contract. The court rejected Kaiser Health Plan’s argument that the contract was inadmissible because the contract provided that its terms would not be used as evidence regarding the reasonable and customary value of services under a minimum payment regulation. The court explained that the jury was asked to determine a distinct quantum meruit valuation issue, which requires a different valuation than the regulatory minimum payment. The court explained that the fair market value of medical services is properly measured by the price that a willing buyer would pay to a willing seller, assuming full knowledge of pertinent facts. The court noted that while “a wide variety of evidence” may bear on fair market value, evidence regarding the hospital’s alleged cost of providing the services is irrelevant and should be excluded.
