## Facts

- Iowa’s Department of Human Services (DHS) administered Medicaid using state and federal funds.
- DHS contracted with Unisys Corporation to serve as Medicaid fiscal agent, including calculating and paying capitation rates to participating HMOs.
- DHS separately contracted with HMOs, including Heritage National Health Plan and Care Choices, Inc., to provide services to enrolled Medicaid recipients in exchange for monthly per-member capitation payments.
- For plan years 1994 and 1995, Unisys allegedly miscalculated capitation rates, resulting in overpayments to the HMOs.
- The State sued Unisys and Paramax for breach of contract and breach of implied warranty to recover the alleged overpayments.
- Unisys filed a cross-petition against Heritage and Care Choices asserting indemnity, contribution, and unjust enrichment based on the alleged overpayments they received and retained.
- The district court granted summary judgment for the HMOs and dismissed Unisys’s contribution and unjust-enrichment claims.
- Unisys appealed the dismissal of contribution and unjust enrichment.

## Issues

1. Whether a defendant sued by the State for overpayments may pursue contribution from HMOs alleged to have shared liability for the same loss, even though the State did not sue the HMOs.
2. Whether Unisys stated a viable unjust-enrichment claim against the HMOs for retaining alleged overpayments, where the payments originated from the State but Unisys might be required to reimburse the State.

## Decision

- The Supreme Court of Iowa reversed the summary judgment dismissing Unisys’s contribution claim and remanded.
- The Court reversed the summary judgment dismissing Unisys’s unjust-enrichment claim and remanded.
- The Court held only that the claims were not barred as a matter of law on the summary-judgment record, not that the HMOs were ultimately liable.

## Legal Principles

- Contribution may be pursued when multiple parties may share common liability for the same injury; a plaintiff’s decision to sue only one party does not, by itself, preclude contribution against others who may be jointly liable.
- On summary judgment, the record is viewed in the light most favorable to the nonmoving party; dismissal is improper if material facts could support common liability or equitable restitution.
- Unjust enrichment requires proof that (1) the defendant received a benefit, (2) at the plaintiff’s expense, and (3) under circumstances making retention unjust.
- A benefit may be “at the expense of” a claimant if the claimant may be required to repay amounts that another party received and retained; whether retention is unjust is often fact-dependent.
- Payment under a contract does not automatically defeat unjust enrichment if the recipient allegedly received amounts beyond what the contractual arrangement authorized.

## Conclusion

The court held that Unisys’s cross-claims for contribution and unjust enrichment against the HMOs could proceed because the summary-judgment record did not eliminate the possibility of shared liability for the same overpayment loss or inequitable retention of excess payments that Unisys might later be required to reimburse.


State ex rel. Palmer v. Unisys Corp., 637 N.W.2d 142 (Iowa 2001)