Facts: Petitioner John Lynch filed suit against Deaconess Medical Center in the Superior Court for Spokane County seeking to recover attorney’s fees after Lynch had successfully pursued a claim for unpaid medical expenses against an insurer on behalf of a patient who had been hospitalized at Deaconess Medical Center. Lynch maintained that as this recovery benefited Deaconess Medical Center insofar as money was paid to Deaconess Medical Center for an account that had previously been deemed uncollectible, he was entitled to attorney’s fees. The trial court granted summary judgment to Deaconess Medical Center, concluding that although Deaconess Medical Center had incidentally benefited from Lynch’s services, no contract in fact or law bound Deaconess Medical Center to pay attorney fees to Lynch. Lynch appealed this decision to the Supreme Court of Washington.

Question(s): Did a quasi contract exist between Lynch and Deaconess Medical Center?

Conclusion: Justice Pearson’s opinion for a unanimous Court held that Deaconess Medical Center owed no attorney’s fees to Lynch, ruling that Deaconess Medical Center had not been unjustly enriched by Lynch’s legal services as it only received payment that was legally owed to it and had in fact explicitly refused Lynch’s services when offered. More generally, the Court concluded that there is no implied promise to pay an attorney whom one has not employed simply because one has derived incidental benefits from their services.

Docket No. 55940-6

Petitioner: John Lynch

(Counsel: David Jackson and Larry J. Butler)

Respondent: Deaconess Medical Center

(Counsel: Bruce W. Gore)

Decided: Thursday, July 27th, 1989

Prevailing Party: Deaconess Medical Center (Respondent)

Vote: 9-0

Opinion: 113 Wn.2d 162 (1989)

Court: Callow1 Court (1989)

Callow

Utter

Brachtenbach

Dolliver

Dore

Pearson

Andersen

Durham

Smith