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Saks v. International Longshore & Warehouse Union-Pacific Maritime Ass'n Benefit Plans

9th CircuitDecember 3, 2015No. 13-56148
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Case Details

Judge(s)
Fletcher, Gould, Christensen
Status — whether other courts must follow this ruling
Unpublished
Procedural Posture — the stage the case had reached
appeal

Related Laws

No specific laws identified for this ruling.

Claim Types

Breach of Contract

Outcome

The Ninth Circuit affirmed summary judgment in favor of ILWU-PMA on the plaintiff's quantum meruit claims for unpaid medical treatments, finding the claims barred by the unclean hands doctrine due to the plaintiff's failure to report criminal convictions and license suspensions while continuing to collect payments.

What This Ruling Means

**What Happened:** Dr. Saks provided medical treatments to union members covered by the International Longshore & Warehouse Union-Pacific Maritime Association Benefit Plans and sought payment for his services. However, while treating patients and receiving payments from the union's health plan, Dr. Saks failed to disclose that he had criminal convictions and his medical license had been suspended. The union benefit plan refused to pay for the treatments, and Dr. Saks sued for the money he claimed he was owed. **What the Court Decided:** The Ninth Circuit Court of Appeals ruled against Dr. Saks. The court found that because he had "unclean hands" – meaning he acted dishonestly by hiding his criminal record and license problems while continuing to collect payments – he could not demand payment for his services. The court upheld a lower court's decision to throw out his case entirely. **Why This Matters for Workers:** This ruling protects union health benefit plans from having to pay providers who engage in fraudulent behavior. For union members, this helps ensure their health plan money isn't wasted on dishonest providers, potentially keeping more funds available for legitimate medical care and maintaining the integrity of their benefit programs.

This summary was generated to explain the ruling in plain English and is not legal advice.

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This ruling information is sourced from public court records via CourtListener.com. Case outcomes, claim types, and summaries are extracted using AI analysis and may be incomplete or inaccurate. It is provided for informational and educational purposes only and does not constitute legal advice.

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