ABIRA MEDICAL LABORATORIES LLC v. FREEDOM LIFE INSURANCE COMPANY OF AMERICA

CourtDistrict Court, E.D. Pennsylvania
DecidedJanuary 10, 2025
Docket2:24-cv-02110
StatusUnknown

This text of ABIRA MEDICAL LABORATORIES LLC v. FREEDOM LIFE INSURANCE COMPANY OF AMERICA (ABIRA MEDICAL LABORATORIES LLC v. FREEDOM LIFE INSURANCE COMPANY OF AMERICA) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania 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. FREEDOM LIFE INSURANCE COMPANY OF AMERICA, (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

ABIRA MEDICAL LABORATORIES, LLC,

Plaintiff, v. CIVIL ACTION NO. 24-2110 FREEDOM LIFE INSURANCE COMPANY OF AMERICA,

Defendant.

OPINION Slomsky, J. January 10, 2025 TABLE OF CONTENTS I. INTRODUCTION................................................................................................................. 3

II. BACKGROUND ................................................................................................................... 4

III. STANDARD OF REVIEW................................................................................................... 6

IV. ANALYSIS ............................................................................................................................. 7 A. The Court Lacks General Personal Jurisdiction Over Defendant ................................... 7

1. Plain Language of Statutes Shows That Defendant Did Not Consent to General Personal Jurisdiction in Pennsylvania ............................................................... 9

a. 42 Pa. Cons. Stat. § 5301 ................................................................................................ 9

b. 15 Pa. Cons. Stat. § 411 ................................................................................................ 10

c. 40 P.S. Insurance § 46 ....................................................................................................11

d. Section 46 Only Provides for Jurisdiction in Pennsylvania Over Foreign Insurance Companies in Certain Cases ......................................................................... 13

2. Pennsylvania Fire Insurance Co. v. Gold Issue Mining & Milling Co. and Mallory v. Norfolk S. Railway Co. Do Not Support Plaintiff's Argument That Defendant Consented to General Personal Jurisdiction in Pennsylvania ........................................... 16 B. The Court Lacks Specific Personal Jurisdiction Over Defendant ................................. 19

V. CONCLUSION ................................................................................................................... 23 I. INTRODUCTION

Before the Court is an important issue of first impression: whether a foreign insurance company consents to general personal jurisdiction in Pennsylvania to be sued by a private party on its own behalf for any cause of action when it obtains a Certificate of Authority issued pursuant to Pennsylvania statute 40 P.S. § 46.1 A Certificate of Authority licenses a foreign insurance company to do insurance business in Pennsylvania. See 40 PA. STAT. AND CONS. STAT. § 46(a). But whether it carries with it a foreign insurance company’s consent to be sued by a private party on its own behalf in Pennsylvania in any case is an open question. For reasons set forth below, the Court answers this question in the negative: there is no general personal jurisdiction over a foreign insurance company sued by a private party on its own behalf in any case in Pennsylvania.

1 40 P.S. § 46 provides in pertinent part:

(a) No insurance company, association, or exchange of another state or foreign government shall do an insurance business within this Commonwealth without first having obtained a certificate of authority from the Insurance Commissioner authorizing such company, association or exchange to do such business. . . .

***

(d)(1) The performance by an insurance company, association, or exchange of another state or foreign government of any act which constitutes the doing of an insurance business within this Commonwealth is equivalent to and shall constitute an appointment by such company, association or exchange of the Secretary of the Commonwealth and his successor or successors in office as its true and lawful attorney upon whom may be served all lawful process in any action, suit or proceeding instituted by or on behalf of the Insurance Commissioner against it arising out of a violation of this section, and the performance of any such act shall be signification of its agreement that such service of process is of the same legal force and validity as personal service of process in this Commonwealth upon such company, association, or exchange.

40 PA. STAT. AND CONS. STAT. § 46 (emphasis added). In this case, Defendant Freedom Life Insurance Company of America (“Defendant”) filed a Motion to Dismiss the First Amended Complaint, arguing that it did not consent in this case to general personal jurisdiction over it in Pennsylvania by obtaining a Certificate of Authority. Because the Court finds that Defendant did not consent in this case to general personal jurisdiction

in Pennsylvania by obtaining a Certificate of Authority issued pursuant to 40 P.S. § 46, and because the Court also lacks specific personal jurisdiction over it, Defendant’s Motion to Dismiss the First Amended Complaint (Doc. No. 8) will be granted. II. BACKGROUND Defendant is a foreign insurance company that holds a Certificate of Authority issued by the Pennsylvania Department of Insurance, authorizing it to conduct insurance business in Pennsylvania. (Doc. No. 6 at ¶ 5.) Plaintiff Abira Medical Laboratories, LLC, doing business as Genesis Diagnostics (“Plaintiff”), is a licensed medical testing laboratory that performs clinical laboratory, pharmacy, genetics, addiction rehabilitation, and COVID-19 testing services at its facilities located in Bucks County, Pennsylvania. (Id. at ¶ 10.) Plaintiff provides these laboratory

testing services to Defendant’s insured members, among others, as an out-of-network provider. (Id. at ¶ 4.) As described in the Amended Complaint, unnamed medical service providers collected specimens from patients around the United States and sent the specimens to Plaintiff for laboratory testing services. (Id. at ¶ 10.) Over one hundred (100) patients for whom Plaintiff performed the laboratory testing are alleged to be insured by Defendant. (Id. at 10, Ex. 1.) Along with the requests for testing services, the medical service providers sent Plaintiff an “assignment of benefits” form executed by each patient insured by Defendant. (Id. at ¶ 11.) The assignment of benefits forms sent to Plaintiff cover the patients’ right to payment for laboratory testing services owed to the patients under their insurance plans with Defendant. (Id. at ¶ 18.) Along with the right to payment, the assignments of benefits also transferred to Plaintiff the patients’ right to sue Defendant for payment. (Id.) Based on these assignments of benefits, Plaintiff billed Defendant for laboratory testing

services it performed on specimens provided by Defendant’s insured members. (See id. at ¶ 13.) Thereafter, Defendant either failed to respond to Plaintiff’s requests for payment or denied the requests. (Id. at ¶¶ 14-15.) As a result, on March 30, 2024, Plaintiff filed the Complaint against Defendant in the Court of Common Pleas of Bucks County, Pennsylvania, alleging that Defendant owed Plaintiff approximately $246,403 for laboratory testing services. (Id. at ¶ 23; Doc. No. 4.) On May 16, 2024, Defendant filed a Notice of Removal, removing the case from state court to this Court based on diversity of citizenship jurisdiction. (Doc. No. 1.) On July 5, 2024, Plaintiff filed a First Amended Complaint. (Doc. No. 6.) The First Amended Complaint asserts four (4) claims against Defendant: (1) breach of contract (Count I); (2) breach of the implied covenant of good faith and fair dealing (Count II); (3) violation of the Families First Coronavirus Response

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ABIRA MEDICAL LABORATORIES LLC v. FREEDOM LIFE INSURANCE COMPANY OF AMERICA, Counsel Stack Legal Research, https://law.counselstack.com/opinion/abira-medical-laboratories-llc-v-freedom-life-insurance-company-of-america-paed-2025.