Aliera Healthcare, Inc. v. Anabaptist Healthshare

CourtCourt of Appeals of Georgia
DecidedJune 5, 2020
DocketA20A0435
StatusPublished

This text of Aliera Healthcare, Inc. v. Anabaptist Healthshare (Aliera Healthcare, Inc. v. Anabaptist Healthshare) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aliera Healthcare, Inc. v. Anabaptist Healthshare, (Ga. Ct. App. 2020).

Opinion

THIRD DIVISION MCFADDEN, C. J., DOYLE, P. J., and HODGES, J.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. Please refer to the Supreme Court of Georgia Judicial Emergency Order of March 14, 2020 for further information at (https://www.gaappeals.us/rules).

June 4, 2020

In the Court of Appeals of Georgia A20A0435. ALIERA HEALTHCARE, INC. v. ANABAPTIST HEALTHSHARE et al.

MCFADDEN, Chief Judge.

This dispute arises from the acrimonious termination of a business

relationship. Aliera Healthcare, Inc. appeals an order appointing a receiver and

granting an interlocutory injunction to Anabaptist Healthshare and its wholly owned

subsidiary, Unity Healthshare, LLC.

The trial court’s extensive findings of fact are not clearly erroneous. Under

those findings, Aliera cannot show that the trial court manifestly abused her

discretion in either ruling. So we affirm.

1. Trial court’s findings of fact.

The trial court’s order was entered after a two-day hearing. We owe deference to her findings of fact. Where, as here, the trial judge hears evidence and sits as the

trier of facts,

[her] findings based upon conflicting evidence are analogous to the verdict of a jury and should not be disturbed by a reviewing court if there is any evidence to support them. . . . [T]he trial court’s decision with regard to questions of fact and credibility must be accepted unless clearly erroneous [and] the reviewing court must construe the evidence most favorably to the upholding of the trial court’s findings and judgment. . . . [T]his standard of review requires us to focus on the findings of fact made by the trial court in [her] order and the evidence supporting those findings, rather than other evidence gleaned from the record, construing it in favor of upholding the trial court’s order.

State v. Rosenbaum, 305 Ga. 442, 449 (2) (826 SE2d 18) (2019) (citations and

punctuation omitted). See also Mondy v. Magnolia Advanced Materials, 303 Ga. 764,

773 (4) (b) (815 SE2d 70) (2018) (Trial court’s order that “expressly specified which

portions of the factual record the judge credited and relied upon as well as the judge’s

legal analysis . . . affect[ed] how the . . . ruling would be reviewed on appeal.”)

So viewed, the record shows that the parties entered into an agreement under

which their complementary products were marketed together. Aliera was tasked with

administering that undertaking and so gained exclusive control over Unity’s

membership roster and website. Anabaptist and Unity came to believe that Aliera was

2 misappropriating funds and so terminated the agreement. Aliera retained control over

the lists and website and used that control to issue opt-out offers to the

members/customers.

Appellant Aliera and appellees Anabaptist and Unity all provide alternatives

to health insurance. Aliera is a for-profit company. Anabaptist is a non-profit, tax-

exempt organization; it manages a health care sharing ministry for members of

Anabaptist communities in Virginia. Health care sharing ministries are non-profit

organizations that facilitate the sharing of certain medical expenses among their

members.

At the relevant time, members of a qualifying health care sharing ministry were

exempt from the Affordable Care Act’s individual mandate, which required persons

to purchase health insurance or pay a tax penalty. See 26 USC § 5000A (a), (d) (1)

& (d) (2) (B). (Congress eliminated the individual mandate tax penalty beginning

January 1, 2019. See Pub. L. No. 115-97, § 11081 (2017).) So the members of

Anabaptist were exempt from the individual mandate. The purchasers of Aliera’s

products were not exempt from the individual mandate.

Aliera determined that the parties’ plans were complementary — and that it

could increase its sales if it could sell its plans side by side with an Affordable Care

3 Act-exempt health care sharing ministry plan. To this end, in 2016, Aliera approached

Anabaptist to propose a relationship between Aliera and Anabaptist. Eventually they

entered the contract at issue.

Under that contract, Anabaptist created Unity, a wholly owned subsidiary, to

offer health care sharing ministry plans.

The contract provided that Anabaptist granted Aliera the exclusive license to

sell and distribute Unity products. It provided that Anabaptist “was the sole and

exclusive owner or authorized licensor of and [would] retain all right, title, and

interest, including all intellectual property rights, in and to the ‘membership roster,’”

an undefined term in the agreement. The contract provided that Aliera remained “the

sole and exclusive authorized non-insurance health care company allowed to market

and sell health care products to Aliera and Unity HealthShare members [and]

retain[ed] all right, title, and interest, including all intellectual property rights, in and

to the Aliera products.”

Anabaptist board chair Tyler Hochstetler testified that under the parties’

contract, member funds collected for Unity products were to be segregated into a

separate bank account that belonged to Unity. Hochstetler also testified that

Anabaptist and Unity trusted that Aliera would properly account for Unity plan assets

4 and that Aliera would keep the Unity plan assets separate from Aliera’s funds. Unity

entrusted Aliera with its member information and plan assets.

Aliera offered its products to the public in conjunction with the Unity plans.

Aliera served as the program administrator for the Unity plans. The marketing

materials for the side-by-side plan offerings emphasized the Unity exemption from

the tax penalty of the Affordable Care Act’s individual mandate.

Some individuals purchased plans that contained only an Aliera product and

some individuals purchased plans that contained only a Unity product. But the vast

majority purchased both. Though those plans were offered side by side, only the

Unity plan was Affordable Care Act-exempt; so Aliera made clear in its

representations to the public and regulators that the plans were legally separate and

distinct. Aliera described itself to insurance regulators as a third-party administrator

of the Unity plans. It also represented to insurance regulators that it was segregating

the Unity plan assets from other funds.

The separate and distinct nature of the Unity plans was also reflected in the

Member Guide, which Aliera drafted. The Member Guide delineated between the

Aliera component and the Unity component of the combined plans. The Member

Guide made clear that the health care sharing ministry was a Unity plan and that the

5 members of that plan were Unity Healthshare members.

Anabaptist representative Hochstetler testified that in January 2018, he learned

for the first time that Aliera was not properly segregating Unity plan assets.

According to Hochstetler, Aliera’s principal, Timothy Moses, who became a member

of Anabaptist’s board, stated at a January 2018 board meeting that since April 2017,

Aliera had not segregated the Unity plan assets, but instead unilaterally allocated

revenues in the manner in which Aliera saw fit, keeping as much of the incoming

member funds for Aliera’s own benefit as it desired. Hochstetler testified that Aliera

did not have Anabaptist or Unity’s permission or authorization to treat member funds

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Aliera Healthcare, Inc. v. Anabaptist Healthshare, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aliera-healthcare-inc-v-anabaptist-healthshare-gactapp-2020.