Springer v. Cleveland Clinic Emp. Health Plan Total Care

When Dr. Jason Springer sued for breach of contract, he was attempting to vindicate his own private rights rather than the rights of the public at large. As such, he did not need to demonstrate concrete and particularized harm to satisfy standing. An invasion of his legal rights was enough. I write separately to explain why.

When the Cleveland Clinic hired Dr. Springer, he enrolled his family in the Cleveland Clinic's employee benefit plan ("Total Care"). As part of his family's relocation from Utah, he needed to transport his infant son-who has been hospitalized since birth-by air ambulance.…