Abira Medical Laboratories, LLC v. Aetna, Inc.

CourtDistrict Court, D. Connecticut
DecidedFebruary 10, 2025
Docket3:24-cv-00931
StatusUnknown

This text of Abira Medical Laboratories, LLC v. Aetna, Inc. (Abira Medical Laboratories, LLC v. Aetna, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Abira Medical Laboratories, LLC v. Aetna, Inc., (D. Conn. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ABIRA MEDICAL LABORATORIES, ) 3:24-CV-00931 (SVN) LLC d/b/a GENESIS DIAGNOSTICS, ) Plaintiff, ) ) v. ) ) AETNA, INC., CVS HEALTH ) February 10, 2025 CORPORATION, ABC COMPANIES 1- ) 100, AND JOHN DOES 1-100, Defendants. RULING AND ORDER ON DEFENDANTS’ MOTION TO DISMISS Sarala V. Nagala, United States District Judge. In this insurance-related action, Abira Medical Laboratories, LLC, alleges that it performed laboratory testing services for insureds of Defendants Aetna, Inc. (“Aetna”), CVS Health, Co. (“CVS Health”), ABC Companies 1-100 and John Does 1-100, for which Plaintiff has not been compensated. Plaintiff brings claims under state common law, although it also seeks to recover benefits and obtain equitable relief under the Employee Retirement Income Security Act (“ERISA”). Aetna and CVS Health have moved to dismiss the complaint in its entirety under Federal Rules of Civil Procedure 8 and 12(b)(6). For the reasons described below, the motion to dismiss is GRANTED, with leave to amend except as to the equitable estoppel and quantum meruit/unjust enrichment claims. I. FACTUAL BACKGROUND The amended complaint contains the following allegations, which are accepted as true for the purpose of this motion. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Plaintiff operates a laboratory business that performs medical testing services on specimens submitted to it. Compl., ECF No. 1, ¶¶ 16–17. Defendant Aetna is a mutual insurance company that provides health insurance services. Id. ¶¶ 2, 7. Defendant CVS Health is a healthcare company that is the parent company of Aetna. Id. ¶ 8. From approximately January 2016 to July 2019, Plaintiff provided laboratory testing services that were ordered or authorized by Aetna and CVS and others, including but not limited

to Defendants ABC Companies 1-100 and John Does 1-100. Id. ¶¶ 2, 23. Plaintiff also alleges that these services were ordered by “physician members of insurance companies . . . , by a non- member physician, or an insured/patient member of an insurance company.” Id. ¶ 1. Plaintiff submitted insurance claims to Defendants to receive payment for the laboratory services performed, which Defendants “were supposed to pay.” Id. ¶¶ 21–22. Plaintiff alleges that Defendants were required to pay such claims, in part, because Defendants entered into insurance contracts with insureds/claimants that required Defendants to pay for laboratory testing services for these insureds/claimants, and that the insureds/claimants assigned to Plaintiff their rights under these insurance contracts by providing their insurance information to Plaintiff for laboratory testing. Id. ¶¶ 19, 28–30, 36. The complaint alleges that approximately two hundred

claims are at issue, id. ¶ 31, though Plaintiff’s briefing on this motion increases that number at least forty-five fold, to approximately 9,000 unpaid claims. See Pl.’s Opp. Br., ECF No. 31 at 18. Defendants processed and paid numerous claims submitted by Plaintiff, such that Plaintiff alleges that it was induced to render more laboratory services for the insureds/claimants of Defendants. Id. ¶¶ 24, 36. Plaintiff also alleges that certain communications from Defendants induced this reliance and that Defendants knew or should have known that their actions would induce such reliance. Id. Eventually, Defendants begin underpaying claims or altogether not paying claims submitted by Plaintiff. Id. Plaintiff alleges that it exhausted administrative remedies concerning the nonpayment of claims by filing appeals when claims were denied. Id. ¶¶ 4, 31. Plaintiff alleges that it may legally recover for the underpaid or unpaid claims, asserting it is a “designated representative” within the meaning of 29 C.F.R. § 2560.503-1(b)(4)1 to secure benefits on behalf of “insureds/claimants,” or that it is otherwise a contract assignee of the contract between Defendants and their insureds, such that it is “in privity” of contract with Defendants. Id.

¶¶ 20, 28–30, 36. Plaintiff brings claims for: breach of contract (Count 1); breach of implied covenant of good faith and fair dealing (Count 2); fraudulent misrepresentation (Count 3); negligent misrepresentation (Count 4); promissory estoppel (Count 5); equitable estoppel (Count 6), and quantum meruit/unjust enrichment (Count 7). Plaintiff does not bring a claim under ERISA, despite alleging that, “[t]o the extent that the contracts relevant to the underlying claims are governed by ERISA, this action is brought to: (1) recover benefits pursuant to 29 U.S.C. § 1132(a)(1)(B), and (2) for equitable relief, pursuant to 29 U.S.C. § 1132(a)(3).” Compl. ¶ 27.2 Defendants have moved to dismiss the complaint on all counts under Rules 8 and 12(b)(6) of the Federal Rules of Civil Procedure. Mot. to Dismiss, ECF No. 24.

II. THRESHOLD ARGUMENTS The Court begins by rejecting two threshold arguments made by Defendants. A. Reliance on Facts Outside of the Complaint First, the Court rejects Defendants’ assertion that, because they do not issue or administer health plans or pay healthcare claims, including the claims at issue in this action, they should be dismissed from this action. Defs.’ Br., ECF No. 24-3 at 13. Defendants do not draw this assertion

1 That section provides, in relevant part: “The claims procedures [under ERISA] do not preclude an authorized representative of a claimant from acting on behalf of such claimant in pursuing a benefit claim or appeal of an adverse benefit determination. Nevertheless, a plan may establish reasonable procedures for determining whether an individual has been authorized to act on behalf of a claimant . . . .” 2 At oral argument, Plaintiff’s counsel stated that, because Plaintiff did not know at the time of the filing of the complaint whether any of the insured/claimants’ plans were governed by ERISA, Plaintiff chose not to allege a standalone claim under ERISA. from the complaint, as Plaintiff does not allege as much. Instead, to support their argument, Defendants have submitted a declaration from a paralegal employed by Aetna Life Insurance Company representing that neither Aetna nor CVS Health “are licensed to issue or administer health benefit plans,” and that they do not “make payments on healthcare claims.” Lund Decl.,

ECF No. 24-1. But Defendants’ reliance on a document outside of the complaint is misplaced. A motion to dismiss pursuant to Rule 12(b)(6) is a challenge to the legal feasibility of a complaint. Goel v. Bunge, Ltd., 820 F.3d 554, 558 (2d Cir. 2016). When evaluating such a motion, courts generally do not look beyond facts in the complaint, documents appended to the complaint or incorporated by reference, and matters of which a court may take judicial notice. Id. at 559. A court may consider an extrinsic document that is “integral” to the complaint if the complaint “relies heavily upon [the document’s] terms and effect.” Id. An integral document is typically “a contract or other legal document containing obligations upon which the plaintiff's complaint stands or falls, but which for some reason—usually because the document, read in its entirety, would undermine the legitimacy of the plaintiff’s claim—was not attached to the complaint.” Id. (citation omitted).

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Bluebook (online)
Abira Medical Laboratories, LLC v. Aetna, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/abira-medical-laboratories-llc-v-aetna-inc-ctd-2025.