The opinion opens: “A deal is a deal, especially in Arizona—a right-to-contract state. With no significant overriding public policy considerations, Arizona holds parties to their deals.” We wonder whether any states view themselves differently. And if the issue of clawing back overpayments is so easily resolved, why does this opinion take so many pages? The trial court accepted the “voluntary payment doctrine,” and the court of appeals decided we needed a contract class, or perhaps an equitable remedies class. The court of appeals distinguished a Division Two case, Wood v. Northwest Hosp. LLC, in which the doctrine was applied to overpayments made to an employee/physician. Whatever equity door the Wood case may have opened, it seems mostly closed.

link to opinion