Atlantic Er Physicians Team Pediatric Associates, Pa v. United Healthcare Group, Inc.

CourtNew Jersey Superior Court Appellate Division
DecidedMarch 13, 2025
DocketA-2031-23
StatusUnpublished

This text of Atlantic Er Physicians Team Pediatric Associates, Pa v. United Healthcare Group, Inc. (Atlantic Er Physicians Team Pediatric Associates, Pa v. United Healthcare Group, Inc.) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Atlantic Er Physicians Team Pediatric Associates, Pa v. United Healthcare Group, Inc., (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-2031-23

ATLANTIC ER PHYSICIANS TEAM PEDIATRIC ASSOCIATES, PA, EMERGENCY CARE SERVICES OF NJ, PA, EMERGENCY PHYSICIAN ASSOCIATES OF NORTH JERSEY, PC, EMERGENCY PHYSICIAN ASSOCIATES OF SOUTH JERSEY, PC, EMERGENCY PHYSICIAN SERVICES OF NEW JERSEY, PA, MIDDLESEX EMERGENCY PHYSICIANS, PA, and PLAINFIELD EMERGENCY PHYSICIANS, PA,

Plaintiffs-Respondents,

v.

UNITEDHEALTH GROUP, INC., UNITEDHEALTHCARE INSURANCE COMPANY, OXFORD HEALTH PLANS (NJ), INC., MULTIPLAN, INC., and UMR, INC.,

Defendants-Appellants. _______________________________ Argued January 22, 2025 – Decided March 13, 2025

Before Judges Gilson, Firko, and Augostini.

On appeal from an interlocutory order of the Superior Court of New Jersey, Law Division, Gloucester County, Docket No. L-1196-20.

Jonathan D. Hacker (O'Melveny & Myers LLP) of the District of Columbia and Maryland bars, admitted pro hac vice, argued the cause for appellants (Stradley Ronon Stevens & Young, LLP, and Jonathan D. Hacker, attorneys for appellants UnitedHealth Group, Inc., UnitedHealthcare Insurance Company, Oxford Health Plans (NJ), Inc. and UMR, Inc.; Sweeney & Sheehan, attorneys for appellant MultiPlan, Inc.; Jonathan D. Hacker, Greg Jacob (O'Melveny & Myers LLP) of the District of Columbia bar, admitted pro hac vice, Ethan Scapellati (O'Melveny & Myers LLP) of the New York bar, admitted pro hac vice, Francis X. Manning, Neal A. Thakkar, Errol J. King, Jr. (Phelps Dunbar LLP) of the Louisiana bar, admitted pro hac vice, Katherine C. Mannino (Phelps Dunbar LLP) of the Louisiana bar, admitted pro hac vice, Taylor J. Crousillac (Phelps Dunbar LLP) of the Louisiana bar, admitted pro hac vice, Craig L. Caesar (Phelps Dunbar LLP) of the Louisiana bar, admitted pro hac vice, and Brittany H. Alexander (Phelps Dunbar LLP) of the Louisiana bar, admitted pro hac vice, of counsel; Robert J. Norcia, on the joint briefs).

Justin C. Fineberg (Lash Goldberg Fineberg LLP) of the Florida bar, admitted pro hac vice, argued the cause for respondents (Lowenstein Sandler, LLP, and Justin C. Fineberg, attorneys; Justin C. Fineberg, Jonathan E. Siegelaub (Lash Goldberg Fineberg LLP) of the Florida bar, admitted pro hac vice, and Kent D. Anderson, of counsel and on the briefs).

A-2031-23 2 Camille Joanne Rosca (Orrick, Herrington & Sutcliffe LLP), Wendy Butler Curtis (Orrick, Herrington & Sutcliffe LLP) of the District of Columbia bar, admitted pro hac vice, Andrew D. Silverman (Orrick, Herrington & Sutcliffe LLP) of the New York bar, admitted pro hac vice, attorneys for amicus curiae Lawyers for Civil Justice; (Wendy Butler Curtis, Andrew D. Silverman and Camille Joanne Rosca, on the brief).

Stone Conroy LLC, attorneys for amici curiae the Chamber of Commerce of the United States of America and the New Jersey Civil Justice Institute (Shalom D. Stone and Rebekah R. Conroy, on the brief).

Shook, Hardy & Bacon LLP and Robert D. Owen (Robert D. Owen LLC) of the Illinois bar, admitted pro hac vice, attorneys for amicus curiae Electronic Discovery Institute (Philip S. Goldberg Robert D. Owen, and Patrick Oot (Shook, Hardy & Bacon LLP) of the District of Columbia bar, admitted pro hac vice, on the brief).

PER CURIAM

This interlocutory appeal involves discovery disputes concerning

electronically stored information (ESI). Defendants UnitedHealth Group, Inc.,

UnitedHealthcare Insurance Company, Oxford Health Plans (NJ), Inc., and

UMR, Inc. (collectively, the United defendants) and MultiPlan, Inc. (MultiPlan)

(collectively, defendants) appeal from a September 12, 2023 order concerning

document review and production of ESI (the ESI Order). The ESI Order directs

the parties to produce all documents identified by their agreed-upon ESI search

A-2031-23 3 terms, except those which are privileged or contain highly proprietary business

information, regardless of whether they are responsive or relevant. Because the

ESI Order violates Rule 4:10-2(a) by compelling defendants to produce

irrelevant documents, and because the order constitutes an abuse of discretion,

we vacate the ESI Order and remand for the entry of an order limiting production

to relevant documents.

I.

Plaintiffs provide emergency medical services to patients throughout New

Jersey, without regard to a patient's ability to pay or their insurance status in

accordance with 42 U.S.C. § 1395dd and N.J.S.A. 26:2H-18.64. The United

defendants are insurers or administrators of employer-sponsored health benefit

plans. In providing medical services, plaintiffs routinely care for patients whose

insurance coverage is either issued, administered, or underwritten by the United

defendants.

On May 23, 2022, plaintiffs filed an amended complaint alleging that the

United defendants leveraged plaintiffs' legal obligation to care for emergency

patients to enrich themselves by forcing plaintiffs out-of-network and

reimbursing plaintiffs for their services at "shockingly low rates." Plaintiffs also

allege that co-defendant MultiPlan, a cost management company, conspired with

A-2031-23 4 the United defendants to underpay claims by offering fraudulent health claim

pricing services.

In their amended complaint, plaintiffs asserted four causes of action: (1)

breach of an implied-in-fact contract (count one); (2) remuneration for quantum

meruit services (count two); (3) violations of the New Jersey Health Claims

Authorization, Processing and Payment Act (HCAPPA), N.J.A.C. 11:22-1.1 to

-1.16 (count three); and (4) violations of the New Jersey Anti-Racketeering Act

(RICO), N.J.S.A. 2C:41-1 to -6.2 (counts four and five).

Plaintiffs' action is related to a series of nationwide litigations between

the United defendants and plaintiffs' affiliates. Indeed, plaintiffs' action in New

Jersey is one of at least ten related civil actions filed against the United

defendants in various jurisdictions since 2017.

On April 3, 2023, the trial court in this matter entered an electronic

discovery stipulation and order to "govern the discovery of [ESI] and any

electronically stored or maintained information." That order required the parties

to collaborate to identify "custodians whose email[s] [were] reasonably believed

to contain relevant ESI for collection" and develop "search parameters, i.e.,

search terms" to search the agreed-upon custodians' records. Thereafter, on

April 21, 2023, the trial court entered an amended discovery-confidentiality

A-2031-23 5 order granting the parties the right to designate as "Confidential" and "Attorneys'

Eyes Only" any document, or portion of a document, containing "highly

sensitive business or personal information."

On April 25, 2023, the trial court conducted a discovery hearing with

counsel for all parties. At the hearing, several discovery issues were addressed,

including relevance objections made by both sides. Specifically, plaintiffs'

counsel "raised an issue that had come up with United in other litigation: that

United was producing documents but making selective redactions based on

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