Consumers For Affordable Health Care v. Iuppa

CourtSuperior Court of Maine
DecidedDecember 21, 2001
DocketKENap-00-37and42
StatusUnpublished

This text of Consumers For Affordable Health Care v. Iuppa (Consumers For Affordable Health Care v. Iuppa) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Consumers For Affordable Health Care v. Iuppa, (Me. Super. Ct. 2001).

Opinion

STATE OF MAINE SUPERIOR COURT

CIVIL ACTION KENNEBEC, ss. DOCKET NO. AP-00-37 AP-00-42 wl he Ke. we hy : Oo eye fd CONSUMERS FOR AFFORDABLE HEALTH CARE, ef al, Petitioners Vv. DECISION AND ORDER SUPERINTENDENT OF INSURANCE, et al., Respondent

This matter is before the court on motion of the Superintendent of Insurance to strike the Attorney General’s independent claim and to dismiss the same. This matter was commenced by the Attorney General filing, on June 26, 2000, a petition for review of final agency action pursuant to MLR. Civ. P. 80C, and independent claim for relief. Petitioner asks the court to find that a decision of the Superintendent of Insurance in regard to the application of Associated Hospital Service of Maine, d/b/a Blue Cross/Blue Shield of Maine, to convert to a stock insurer was in violation of statute, affected by error of law or unsupported by substantial evidence on the record. The Attorney General further seeks to modify the decision to require an updated appraisal and appropriate compensation for the charitable foundation created in conjunction with legislation authorizing the conversion. In a separate action, subsequently consolidated by this court, Consumers for Affordable Health Care, on June 5, 2000, brought a petition for review of final agency action pursuant to MLR. Civ. P. 80C seeking review

of the action. This matter involves a challenge by the Consumers for Affordable Health Care and the Attorney General to the decision of the Superintendent of Insurance to approve, subject to conditions, the conversion of Blue Cross/Blue Shield of Maine to a domestic stock insurer and the acquisition of substantially all of the assets of Blue Cross/Blue Shield by a subsidiary of Anthem Insurance Companies, Inc. Legislation enacted by the Legislature in 1997 addressed the conversion issue and established two requirements.

First, the Attorney General was to create a charitable trust with court approval and, second, the Superintendent of Insurance was given the responsibility for approving the terms of the conversion and acquisition of Blue Cross/Blue Shield of Maine. Under the legislation, the charitable trust created by the Attorney General is to receive the fair market value from the sale of Blue Cross/Blue Shield assets. In its independent claim, the Attorney General secks to exercise his implied powers with regard to charitable organizations by challenging the value of Blue Cross/Blue Shield as determined by the Superintendent in an effort to require additional funds to be deposited into the charitable trust. It is an independent claim because the Superintendent of Insurance clearly has no authority to order Anthem to provide additional funds now that the Superintendent's decision has been rendered and the conversion has taken place.

The Superintendent seeks dismissal of the independent action because he believes the essence of the Attorney General’s administrative appeal is that the Superintendent did not properly determine the fair market value of Blue Cross/Blue Shield of Maine and this challenge is redundant of his 80C petition for review. The

Superintendent asserts that the Attorney General’s authority over charities does not create an independent right to file this action against a-non-charity such as the Superintendent of Insurance because, among other reasons, the statutory jurisdictional basis authorizing the Attorney General to enforce “due application of funds given or appropriated to public charities within the state and prevent breaches in trust in the administration thereof” (5 M.R.S.A. § 194) does not provide a basis upon which the Attorney General can sue a non-charity, ”. . . much less another arm of state government.” Petitioner’s motion, p.5. The Superintendent further argues that the statutes governing the transaction contemplate that the Administrative Procedure Act (APA) and Rule 80C provides the exclusive remedy for challenging the Superintendent's decision. The Superintendent goes on to complain that the Attorney General's claim is not an “independent” action in that the administrative appeal and the independent claim make the same factual allegation and seek the same relief. Independently, Anthem Insurance Companies, Inc. and Anthem Health Plans of Maine, Inc. challenge the Attorney General’s independent claim by arguing that it is a “noncognizable collateral attack” on the decision and is barred by the Law Court decision of Fitzgerald v. Baxter State Authority, 385 A.2d 189 (Me. 1978). Anthem’s motion, p. 1. Anthem, too, argues that the APA review is the exclusive avenue for challenging the failure of the Superintendent to comply with the law and further asserts that the Attorney General’s claim is a collateral attack which ignores the Superintendent’s ruling. For support of this proposition, it cites Lovell v. One Bancorp, 614 A.2d 56 (Me. 1992). Anthem also argues that the Attorney General should be estopped from making such a claim since his activity with the charitable trust and that

trust approval of the transaction constitutes a waiver of such complaint. To all this, the Attorney General relies upon his interpretation of the common law and statutory duties as chief law enforcement officer of Maine, as well as the more specific administrative review responsibility in the statute. See 5 M.R.S.A. §§ 194 & 194-A. The Attorney General cites a large body of cases approving the exercise of his authority in dealing with charitable trust matters including language from Lund ex rel. Wilbur v. Pratt, 308 A.2d 554 (Me. 1973) which confirms that the Attorney General is endowed with all common law powers. The Wilbur Court explained:

The Attorney General... may, in the absence of some express legislative

restriction to the contrary, exercise all such power and authority as public

interest may, from time-to-time require, and may institute, and conduct

all such actions and proceedings as he deems necessary for the

enforcement of the laws of the state, the preservation of order, and the

protection of public rights.” Id. at 558. (Emphasis in original).

It is interesting to note that the Attorney General has emphatically argued that the court should not consider the independent claim until the Rule 80C review has been completed. Obviously, he seeks to reserve the right to seek more consideration from the acquiring corporation than authorized under the Superintendent's decision if the court agrees to modify the conclusion by the Superintendent. He wants “a second bite

at the apple.” For this reason, the court has determined that the motion to dismiss the independent claim must be determined first and consider whether it is truly an “independent” claim, whether there is clear authority apart from the legislative scheme of administrative review or whether Rule 80C is the sole remedy and authority in the Attorney General under the circumstances.

Consumers lends support to the Attorney General’s position that he is

authorized by the common law to bring the independent claim. Consumers for Affordable Health Care argues that the independent claim is simply asking the court to invoke its equitable jurisdiction over the matter and to provide a remedy of disgorgement if an updated valuation should be approved in excess of $81.69 million.

The Attorney General’s independent claim is, at its essence, an attack on the inaction of the Superintendent of Insurance.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

York Mutual Insurance v. Superintendent of Insurance
485 A.2d 239 (Supreme Judicial Court of Maine, 1984)
Fitzgerald v. Baxter State Park Authority
385 A.2d 189 (Supreme Judicial Court of Maine, 1978)
Coker v. City of Lewiston
1998 ME 93 (Supreme Judicial Court of Maine, 1998)
In Re Wage Payment Litigation
2000 ME 162 (Supreme Judicial Court of Maine, 2000)
Lund Ex Rel. Wilbur v. Pratt
308 A.2d 554 (Supreme Judicial Court of Maine, 1973)
Kimball v. Land Use Regulation Commission
2000 ME 20 (Supreme Judicial Court of Maine, 2000)
CWCO, INC. v. Superintendent of Ins.
1997 ME 226 (Supreme Judicial Court of Maine, 1997)
MAINE AFL-CIO v. Superintendent of Ins.
595 A.2d 424 (Supreme Judicial Court of Maine, 1991)
Lovell v. One Bancorp
614 A.2d 56 (Supreme Judicial Court of Maine, 1992)
City of Bridgeport v. Debek
554 A.2d 728 (Supreme Court of Connecticut, 1989)

Cite This Page — Counsel Stack

Bluebook (online)
Consumers For Affordable Health Care v. Iuppa, Counsel Stack Legal Research, https://law.counselstack.com/opinion/consumers-for-affordable-health-care-v-iuppa-mesuperct-2001.