DRS. ELLIS, ROJAS, ROSS & DEBS, INC. v. UMR, Inc.

CourtDistrict Court, S.D. Florida
DecidedMarch 9, 2025
Docket1:24-cv-20428
StatusUnknown

This text of DRS. ELLIS, ROJAS, ROSS & DEBS, INC. v. UMR, Inc. (DRS. ELLIS, ROJAS, ROSS & DEBS, INC. v. UMR, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
DRS. ELLIS, ROJAS, ROSS & DEBS, INC. v. UMR, Inc., (S.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Case No. 24-cv-20428-GAYLES

DRS. ELLIS, ROJAS, ROSS & DEBS, INC., D/B/A KENDALL ANESTHESIA ASSOCIATES,

Petitioner,

v.

UMR, INC.,

Respondent. _______________________________________/

ORDER

THIS MATTER comes before the Court on Respondent UMR, Inc.’s Motion to Dismiss (the “Motion”). [ECF No. 11]. The Court has reviewed the Motion and the record and is otherwise fully advised. As set forth below, the Motion is granted. BACKGROUND I. The No Surprises Act In 2020, Congress enacted the No Surprises Act (“NSA”), legislation which “modified portions of the Public Health Services Act, the Internal Revenue Code, and the Employee Retirement Income Security Act . . . to end surprise medical billing by ensuring that certain out- of-network providers . . . are treated the same as in-network providers.” Med-Trans Corp. v. Capital Health Plans, Inc., 700 F. Supp. 3d 1076, 1079 (M.D. Fla. 2023) (citing 42 U.S.C. §§ 300gg et seq.). As relevant here, the NSA creates a standardized process for out-of-network providers to submit their bills to insurance companies. 42 U.S.C. § 300gg-112(a)(3). If the parties disagree over the amount owed or the insurance company refuses to pay, the parties participate in open negotiations. § 300gg-112(b)(1)(A). Should negotiations fail, the parties’ dispute goes to Independent Dispute Resolution (“IDR”). § 300gg-112(b)(1)(B). This case deals with whether the Court has subject matter jurisdiction to confirm an award issued pursuant to an NSA-mandated IDR.

II. The Parties’ IDR and Subsequent Litigation Petitioner Drs. Ellis, Rohas, Ross & Debs, Inc. d/b/a Kendall Anesthesia Associates (“Petitioner”) is a provider of medical anesthesia services. Respondent UMR, Inc. (“Respondent”) is a third-party administrator for self-insured health plans. Petitioner and Respondent do not have a contract setting the rates for the medical services Petitioner provides to participants of plans administered by Respondent. Petitioner, therefore, is “out-of-network” with respect to Respondent. Following a dispute over the amount Respondent owed Petitioner for medical services, the parties participated in an IDR in accordance with the NSA. On April 21, 2023, the IDR entity issued an award in favor of Petitioner in the amount of $2,807.25, to be paid within 30 calendar days (the “IDR Award”). Respondent did not timely pay the IDR Award.

On February 2, 2024, while awaiting payment from Respondent, Petitioner filed this action petitioning the Court to confirm the IDR Award pursuant to Section 9 of the Federal Arbitration Act (“FAA”) (the “Petition”). [ECF No. 1]. It is undisputed that, on February 29, 2024, Respondent paid Petitioner the full amount of the IDR Award. Respondent now moves to dismiss for lack of subject matter jurisdiction, arguing that (1) in light of its payment of the IDR Award, the case is now moot and (2) even if the case is not moot, the Petition presents no independent basis for the Court to confirm the award. The Court agrees. STANDARD OF REVIEW A motion to dismiss for lack of subject matter jurisdiction brought pursuant to Federal Rule of Civil Procedure 12(b)(1) may present either a facial or a factual challenge to the complaint. See McElmurray v. Consol. Gov’t, 501 F.3d 1244, 1251 (11th Cir. 2007). In a facial challenge, a court

is required only to determine if the plaintiff has “sufficiently alleged a basis for subject matter jurisdiction.” Id. at 1251. By contrast, a factual attack “challenge[s] ‘the existence of subject matter jurisdiction in fact, irrespective of the pleadings, and matters outside the pleadings . . . are considered.’” McElmurray, 501 F.3d at 1251 (quoting Lawrence v. Dunbar, 919 F.2d 1525, 1529 (11th Cir. 1990)). Here, Respondent asserts a factual challenge to this Court’s jurisdiction. But, ultimately, “[t]he burden for establishing federal subject matter jurisdiction rests with the party bringing the claim.” Sweet Pea Marine, Ltd. v. APJ Marine, Inc., 411 F.3d 1242, 1247 (11th Cir. 2005). DISCUSSION “Article III of the United States Constitution requires a live case or controversy at the time

a federal court decides the case, and a federal court has no authority to give opinions upon moot questions.” Philippeaux v. Apartment Inv. & Mgmt. Co., 598 F. App’x. 640, 642–43 (11th Cir. 2015) (internal quotations omitted). “The doctrine of mootness provides that the requisite personal interest that must exist at the commencement of the litigation (standing) must continue throughout its existence (mootness).” KH Outdoor, L.L.C. v. Clay Cnty., Fla., 482 F.3d 1299, 1302 (11th Cir. 2007). “A case is moot when events subsequent to the commencement of a lawsuit create a situation in which the court can no longer give the plaintiff meaningful relief.” Philippeaux, 598 F. App’x at 643 (quoting Jews for Jesus, Inc. v. Hillsborough Cnty. Aviation Auth., 162 F.3d 627, 629 (11th Cir.1998)). Respondent argues that this action no longer presents a live case or controversy because it has paid the IDR award. The Eleventh Circuit has not directly addressed whether the payment of an arbitration award renders a petition to confirm that award moot. However, both the Second Circuit in Stafford v. International Business Machines Corp., 78 F. 4th 62 (2d Cir. 2023), and the

Third Circuit in Teamsters Local 177 v. United Parcel Service, 966 F.3d 245 (3d Cir. 2020), have addressed the issue, albeit with opposite results. In Stafford, the petitioner obtained an arbitration award against IBM, her former employer. She then filed a petition under the FAA in federal court to confirm the award. Although IBM had already paid the arbitration award in full, the district court granted the petition and confirmed the award. On appeal, the Second Circuit reversed and found that after IBM satisfied the award, “the petition [was] moot because [the petitioner lacked] any concrete interest in the confirmation.” Stafford, 78 F.4th at 68. In addition, the Second Circuit held that the petitioner’s “statutory right to seek confirmation under the FAA” was not “itself enough to create a ‘live’ controversy” and that she “fail[ed] to show that holding an unconfirmed arbitration award is itself a concrete injury

that ‘has a close relationship to a harm traditionally recognized as providing a basis for a lawsuit in American courts.’” Id. at 69 (quoting TransUnion, LLC v. Ramirez, 141 S. Ct. 2190, 2205 (2021)). In Teamsters, decided over three years before Stafford, the petitioner obtained an arbitration award against United Parcel Service (“UPS”). The arbitration award ordered UPS to “cease and desist” certain actions that violated the parties collective bargaining agreement. After UPS violated the arbitration award, the petitioner moved to confirm it in federal court. The district court dismissed for lack of subject matter jurisdiction.

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Related

Sweet Pea Marine, Ltd. v. APJ Marine, Inc.
411 F.3d 1242 (Eleventh Circuit, 2005)
KH Outdoor, L.L.C. v. Clay County, Florida
482 F.3d 1299 (Eleventh Circuit, 2007)
McElmurray v. CONSOLIDATED GOV'T, AUGUSTA-RICHMOND COUNTY
501 F.3d 1244 (Eleventh Circuit, 2007)
Dolcie Lawrence v. Peter Dunbar, United States of America
919 F.2d 1525 (Eleventh Circuit, 1990)
TransUnion LLC v. Ramirez
594 U.S. 413 (Supreme Court, 2021)

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DRS. ELLIS, ROJAS, ROSS & DEBS, INC. v. UMR, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/drs-ellis-rojas-ross-debs-inc-v-umr-inc-flsd-2025.