Liljeberg v. Health Services Acquisition Corp.

Health Services Acquisition Corporation (plaintiff) negotiated with business promoter John Liljeberg, Jr. (defendant) to purchase rights to operate a planned Kenner, Louisiana hospital, and separately, while negotiating that deal, Liljeberg was also negotiating with Loyola University to build a hospital on land he would purchase from the university, though only one hospital could actually be built given a state licensing limitation. Health Services sued Liljeberg seeking a declaratory judgment regarding his claimed but undocumented agreement for continued employment; Judge Robert Collins decided the case without a jury, ruling for Liljeberg in a way that let him proceed with the Loyola sale, and a divided court of appeals affirmed. Ten months later, Health Services learned Judge Collins sat on Loyola's Board of Trustees and was aware his ruling benefitted the university, though he had learned of that connection only a few days after issuing his decision; Health Services' motion to vacate was denied by Judge Collins, then by a different district judge on remand for fact-finding, before the court of appeals reversed and Liljeberg appealed.