Bed Bath & Beyond Inc. v. Anthem Inc

CourtDistrict Court, N.D. Alabama
DecidedApril 7, 2025
Docket2:22-cv-01256
StatusUnknown

This text of Bed Bath & Beyond Inc. v. Anthem Inc (Bed Bath & Beyond Inc. v. Anthem Inc) is published on Counsel Stack Legal Research, covering District Court, N.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bed Bath & Beyond Inc. v. Anthem Inc, (N.D. Ala. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

Alaska Air Group, Inc., et al., Plaintiffs, v. No. 2:21-cv-01209-RDP Anthem, Inc., et al., Defendants.

JetBlue Airways Corporation, et al., Plaintiffs, v. No. 2:22-cv-00558-RDP Anthem, Inc., et al., Defendants.

Bed Bath & Beyond Inc., et al., Plaintiffs, No. 2:22-cv-01256-RDP v. Anthem, Inc., et al., Defendants.

MEMORANDUM OPINION AND ORDER These cases are before the court on Issuing Defendants’ Motion to Compel UnitedHealth Group, Incorporated (“United”) to Produce Plaintiff-Specific Bid Information. (Doc. # 542).1 More specifically, Defendants’ Motion seeks to compel non-party United to produce “United’s internal communications and analyses relating to the bids it made to these Plaintiffs for the services at issue in these cases.” (Id. at 2).2 United opposes Defendants’ Motion because (1) the information sought

1 For efficiency, the court will only cite to relevant documents in the Alaska Air case where the cited documents were also filed in the JetBlue case, Case No. 2:22-cv-00558-RDP, and the Bed Bath & Beyond case, Case No. 2:22-cv-01256-RDP.

2 In light of the information sought via this Motion, and the fact that United has agreed to produce its Plaintiff- Specific Bids and how it’s ASO prices are set, the court notes that this title is somewhat misleading. consists of highly sensitive internal communications and analyses regarding its competitive bids for the Plaintiffs’ health plan business, (2) the production would be burdensome, and (3) the disclosure of the requested information would risk further harm to competition as well as substantial harm to United’s business. (Doc. # 550 at 2). The Motion is fully briefed (Docs. 542, 550, and 562), and the court heard argument from Defendants and United on this Motion at the

April 4, 2025 status conference. I. Background On March 12, 2024, Defendants issued a subpoena to non-party United, one of the Blues’ primary competitors, for the production of a significant volume of documents over a sixteen-year period. (Doc. # 538-2). United objected to the subpoena on the basis that its scope was unreasonable. (Doc. # 550 at 3). After a year of negotiations, Defendants narrowed the scope of their initial requests, and Defendants and United reached agreement on the “vast majority” of the subpoena’s requests. (Doc. # 537 at 1). Pursuant to those negotiations, United has agreed to produce a substantial amount of

responsive information, including the following: • Nationwide enrollment data for United’s national network products (Request for Production 2).

• Ordinary course financial information on United’s Plaintiff customers (Request for Production 3).

• A description of how United’s ASO prices are set (Request for Production 4).

• Documents discussing United’s expansion or contraction of its offerings for National Accounts (Request for Production 6).

• United’s nationwide network provider counts covering the relevant period (Request for Production 7).

2 • Plaintiff bid documents not otherwise produced by Plaintiffs and their consultants (Request for Production 8).

• Documents discussing facts regarding National Accounts competition and competitors (Requests for Production 9 and 10).

• United’s deposition transcript and exhibits from the MDL class actions (Request for Production 16).

• United’s document productions in the MDL class actions (Request for Production 17) (Doc. # 550 at 4-5). United contends that this information “provides Defendants with a thorough and detailed view of United’s bids for the Plaintiffs and its role in competing for National Accounts customers.” (Id. at 5). As noted above, it appears United has agreed to produce information reflecting not only what its bids for Plaintiffs’ business actually were, but also how it sets ASO prices. And United has agreed to produce its document productions from the MDL. Not satisfied with this information, however, Defendants seek documents reflecting United’s highly sensitive internal communications and analyses regarding its competitive bids for Plaintiffs’ health plan business. II. Legal Standard “Rule 45 is the proper vehicle for obtaining documents and other materials from nonparties relevant to a pending lawsuit.” Landstar Glob. Logistics, Inc. v. Haskins, 2011 WL 13176155, at *1 (M.D. Fla. Jan. 25, 2011). But it “must be read in conjunction with Rule 26 [which] clearly defines the scope of discovery for all discovery devices.” Id. Rule 26(b)(1) provides that: Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties’ relative access to relevant information, the parties’ resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit. Information within this scope of discovery need not be admissible in evidence to be discoverable. 3 Fed. R. Civ. P. 26(b)(1). “[T]he relevance of information sought in discovery depends on the claims asserted in the underlying action and the legal standards that govern those claims.” Jordan v. Comm'r, Miss. Dep’t of Corr., 947 F.3d 1322, 1329 (11th Cir. 2020). Rule 45 imposes a requirement upon the party or attorney issuing a subpoena to take reasonable steps to avoid imposing undue burden on the non-party subject to the subpoena. Aeritas,

LLC v. Delta Airlines, Inc., 2013 WL 454452, at *2 (N.D. Ga. Feb. 7, 2013) (citing Fed. R. Civ. P. 45(c)(1)). “The undue burden analysis requires the court to ‘balance the interests served by demanding compliance with the subpoena against the interests furthered by quashing it.’” Jordan v. Comm'r, Mississippi Dep’t of Corr., 947 F.3d 1322, 1337 (11th Cir. 2020) (quoting 9A Wright & Miller, Federal Practice and Procedure § 2463.1 (3d ed. 2019)). “The status of the subpoena recipient as a non-party is also a factor that can weigh against disclosure in the undue burden inquiry.” Jordan, 947 F.3d at 1337 (quoting Wiwa v. Royal Dutch Petroleum Co., 392 F.3d 812, 818 (5th Cir. 2004) (“[I]f the person to whom the document request is made is a non-party, the court may also consider the expense and inconvenience to the non-party.”)). “The burden on the

non-party is particularly great when the party issuing the subpoena seeks private information.” Castleberry v. Camden Cnty., 331 F.R.D. 559, 563 (S.D. Ga. 2019) (quoting Pinehaven Plantation Properties, LLC v. Mountcastle Family LLC, 2013 WL 6734117, at *2 (M.D. Ga. Dec. 19, 2013) III. Analysis United, a non-party to these cases, is one of Defendants’ competitors for Plaintiffs’ business. Nevertheless, Defendants seek United’s private, highly sensitive, internal communications and analyses about its bids for Plaintiffs’ health plan business. (Doc. # 542). Defendants’ Motion simply argues that that they need this information for “necessary context.” (Doc. # 542 at 6). But, United has agreed to provide the information it produced in the 4 MDL in this case, so apparently the documents currently at issue were not needed in the MDL.

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Related

Wiwa v. Royal Dutch Petroleum Co.
392 F.3d 812 (Fifth Circuit, 2004)
Richard Jordan v. Georgia Department of Corrections
947 F.3d 1322 (Eleventh Circuit, 2020)

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Bed Bath & Beyond Inc. v. Anthem Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bed-bath-beyond-inc-v-anthem-inc-alnd-2025.