“Leakage” of patients was described in an earlier chapter in which a patient leaves or goes outside a health care system for care that can be received or provided by the clinical staff of the organization. This can be a problem for two reasons: (a) monetary or (b) health care quality. The first reason is obvious; when an insured patient leaves, so goes revenue. For ACO organizations, the concern is the same, monetarily and in terms of quality. The belief is that a set of providers who know the patient and can understand their needs in a uniform way can provide better quality care to the patient. In fact, an organization like iorahealth is built on that premise. In this chapter, Steward has sued a physician in their organization because the individual is not preventing leakage. Assuming you are the attorney for Steward, what would be the basis for your case? What if you were the defendant’s attorney?