P.A. May Proceed with Unjust Enrichment Claim Against Zurich, Judge Rules

BALTIMORE — A Maryland federal judge has refused to dismiss an unjust enrichment/quantum meruit claim brought by a reinsurance program administrator against Zurich American Insurance Co., ruling that the claim alleges a reasonable expectation of compensation. Tethys Health Ventures LLC v. Zurich American Insurance Co., No. 11-2761 (D. Md.).

On June 1, Judge William D. Quarles Jr. of the U.S. District Court for the District of Maryland further ruled that the claim is not barred by the program administrator agreement and satisfies New York’s statute of frauds.

Tethys provides managed care organizations with “transplant risk management and government program advocacy” …