Plaintiff, an outpatient surgical facility, sued Defendant, a third-party administrator for an insurance company, under a promissory estoppel theory after Defendant did not pay Plaintiff the full amount Plaintiff billed for a patient’s surgery. Court properly granted Defendant’s motion for summary judgment. Plaintiff did not establish that Defendant made a clear and unambiguous promise regarding the reimbursement. The parties agreed that the reimbursement rate would be 60%, but there was no agreement regarding the basis for calculating the reimbursement amount. Plaintiff also did not demonstrate that its reliance on any alleged promise was reasonable. Plaintiff failed to provide any compelling reason why an insurance company would agree to pay a provider based on the provider’s unilaterally determined charges. (NEVILLE and SIMON, concurring.)
Illinois Appellate Court
Civil Court
Promissory Estoppel