Federal court grants doctor's request to send lease dispute regarding Hannibal office space back to state court

By Charmaine Little | Feb 6, 2019

ST. LOUIS – The U.S. District Court for the Eastern District of Missouri recently granted a physician's motion to remand her lease dispute with a medical group to Marion County Circuit Court.

In a Feb. 1 ruling, U.S. Magistrate Judge Patricia L. Cohen granted the motion to remand filed by Dr. Linda Cooke and Lindan LLC in their suit against Quincy Physicians & Surgeons Clinics, which does business as Quincy Medical Group (QMG). In the ruling, Cohen also denied QMG's motion to dismiss the suit.

Cooke, a physician and member of Lindan, leased office space from Lindan in Hannibal until she transferred her practice to QMG, court filings said.

QMG offered a lease agreement to Lindan and told Cooke she would be able to terminate the lease whenever she left QMG, so Cooke signed the agreement, court filings said. Six months later, Lindan and QMG agreed on lease terms, but never said it would end if/when Cooke left QMG. 

Cooke later resigned, and QMG refused to leave the building, court filings said. Lindan and Cooke then sued QMG in Marion County Circuit Court claiming the lease and employment agreements are void because of fraudulent inducement. Cooke also requested monetary relief for fraud, conversion, detrimental reliance/promissory estoppel, and unjust enrichment. QMG then removed the case to the district court.

The plaintiffs then moved to have the case remanded back to the state court and QMG moved to have the case dismissed.

In the ruling, the court granted the plaintiffs’ motion to remand the case to state court, saying there isn’t complete diversity between the parties in the case, noting Lindan members live in Illinois and Missouri and QMG is an Illinois company. Since Lindan and QMG are both Illinois corporations, complete diversity is not a factor, so this court lacks subject matter jurisdiction and the case is remanded back to state court, the ruling said.

The court also dismissed QMG”s motion to dismiss without prejudice as moot.

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