Class Action Forces MRO Corporation to Return $2.5 Million in Unlawful Medical Records Fees to North Carolina Patients

MRO Corporation is one of the largest processors of medical-record requests in the United States, contracting with hospitals and clinics to fulfill patient and attorney records requests on the provider's behalf. When North Carolina patients requested copies of their own records, MRO collected the fees directly, and those fees were supposed to stay within limits set by the North Carolina Medical Records Fee Act: 75 cents per page for the first 25 pages, 50 cents for pages 26 through 100, and 25 cents per page above that.

Leland Davis filed suit in Durham County Superior Court in 2022 after discovering he had been charged more than the statute allowed. The complaint alleged violations of both the Medical Records Fee Act and the North Carolina Debt Collection Act, claiming that MRO's above-cap charges constituted unlawful collection of a debt.

MRO pushed back on multiple fronts. The company argued the Medical Records Fee Act did not create a private right of action for patients to sue, that the debt-collection and unfair-practices statutes were inapplicable to records fees, and that patients who paid without objection had forfeited any refund claim under the voluntary-payment doctrine. Class counsel Ed Maginnis and Karl Gwaltney of Maginnis Howard defeated those defenses at the certification stage and kept the case moving toward trial.

The parties reached a settlement approved by Judge Michael O'Foghludha on September 26, 2024. The $2.5 million fund covered 6,858 class members: all North Carolina patients who paid MRO-processed records fees exceeding the statutory cap between October 1, 2019, and March 31, 2023. After deductions for attorney fees, litigation costs, notice administration, and a service award to the named plaintiff, each class member received a full refund of the excess charges they paid, totaling $164,835.19 across the class, plus an additional payment of approximately $205.89 per violation as a statutory penalty.

Class members did not need to file a claim; the settlement administrator identified and paid eligible patients automatically from MRO's own billing records.