Specifically, the complaint alleges that the Mayo Clinic charges uninsured patients rates that are significantly higher than the rates charged to insured patients or patients covered by Medicare or Medicaid by setting charges for medical services and supplies at highly inflated rates that bear no connection to the actual cost of providing the service. As a "non profit" organization, Mayo promises the government to operate in a charitable fashion, but does not.

More specifically, the complaint alleges that Sawyer, who was uninsured, was diagnosed with progressive liver failure in February of 2004. She spent $190,000 on treatment and sought a liver transplant. She paid for this by cashing in her 401k. However, after all payments were received, Mayo told Sawyer that she was not a candidate for a transplant and that she was in fact, terminal. She believes that Mayo significantly exceeded the rated charged to insured patients for the same services in violation of Florida's Uniform Deceptive Trade Practices Act.