H. v. United Healthcare Insurance Company

CourtDistrict Court, D. Utah
DecidedFebruary 10, 2025
Docket2:24-cv-00531
StatusUnknown

This text of H. v. United Healthcare Insurance Company (H. v. United Healthcare Insurance Company) is published on Counsel Stack Legal Research, covering District Court, D. Utah primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
H. v. United Healthcare Insurance Company, (D. Utah 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH

WILLIAM H., and J.H.,

RULING & ORDER

Plaintiffs, Case No. 2:24-cv-00531

v. District Court Judge Robert J. Shelby

UNITED HEALTHCARE INSURANCE Magistrate Judge Dustin B. Pead COMPANY, UNITED BEHAVIORAL HEALTH and SPLUNK, INC.,

Defendants.

This case is referred to Magistrate Judge Dustin B. Pead under 28 U.S.C. § 636(b)(1)(A).1 Before the Court is the parties’ stipulated motion to permit Plaintiffs William H. and J.H. (collectively “Plaintiffs”) to proceed anonymously in this case.2 For the reasons stated below, the court rules as follows and grants the motion. BACKGROUND This case involves Defendants United Healthcare Insurance Company, United Behavioral Health and Splunk’s (collectively “Defendants”) denial of benefits for J.H’s mental health treatment at BlueFire and Crossroads Treatment Centers.3 In support of their appeal, Plaintiffs

1 ECF No. 18, Notice of Non-Consent. 2 ECF No. 30, Motion to Proceed Under Initials. Plaintiffs filed their Motion in response to Judge Robert J. Shelby’s January 22, 2025 Order requiring Plaintiffs to either file an amended complaint under their full names or file a motion for leave to proceed under initials. See, ECF No. 27, Docket Text Order. 3 ECF No. 1, Complaint. provide a detailed account of J.H.’s struggles as a minor, including but not limited to experiencing seizures, psychosis, self-medicating through substance abuse and extensive behavioral problems.4 Plaintiffs also present evidence from J.H’s medical records asserting that J.H.’s treatment should have been covered by Defendants. These records include sensitive and personal information about J.H’s mental health and substance abuse as a minor.5

LEGAL STANDARDS Under Rule 10 of the Federal Rules of Civil Procedure, “[t]he title of the complaint must name all the parties.”6 However, with respect to minors, Federal Rule 5.2 provides that minors may be named by initials unless the court orders otherwise.7 No provision in the federal rules explicitly permits “suits by persons using fictitious names” or “anonymous plaintiffs ”8 and proceeding under pseudonym “is, by all accounts, an unusual procedure.”9 Nonetheless, courts do recognize “exceptional circumstances” that may warrant “some

4 See generally id. 5 Id. 6 Fed. R. Civ. P. 10(a) (“the title of the complaint must name all the parties”);see also Fed. R. Civ. P. 17(a) (“An action must be prosecuted in the name of the real party in interest”).. 7 Fed. R. Civ. P. 5.2(a)(3). 8 National Commodity & Barter Association, National Commodity Exchange v. Gibbs, 886 F.2d 1240, 1245 (10th Cir. 1989). 9 Doe v. Weber State University, 2021 U.S. Dist. LEXIS 210538 at *6 (D. Utah Oct. 29, 2021) (citing Femedeer v. Haun, 227 F.3d 1244, 1246 (10th Cir. 2000) (internal quotation marks omitted)). form of anonymity in judicial proceedings.”10 Exceptional circumstances include circumstances “involving matters of a highly sensitive and personal nature, real danger of physical harm, or where the injury litigated against would be incurred as a result of the disclosure of the plaintiff’s identity.”11 In deciding whether to preserve anonymity, the court has broad discretion12 and must

weigh any “exceptional circumstances” against “the public’s interest in access to legal proceedings.”13 Lawsuits are generally viewed as open, public events, but the presumption of open courts can yield to anonymity when exceptional circumstances exist.14 If a court grants permission for a plaintiff to proceed anonymously, “it is often with the requirement that the real names of the plaintiffs be disclosed to the defense and the court but kept under seal thereafter.”15 When no permission is granted, “the federal courts lack jurisdiction over the unnamed parties, as a case has not been commenced with respect to them.”16

10 Free Speech Coalition v. Anderson, 2023 U.S. Dist. LEXIS 111976 at *4 (D. Utah June 27, 2023) (citing Femedeer, 227 F.3d at 1246). 11 Femedeer, 227 F.3d at 1246. 12 United States DOJ v. Utah DOC, 2017 U.S. Dist. LEXIS 34882 at *3 (D. Utah March 10, 2007) (unpublished) (citing Lindsey v. Dayton-Hudson Corp., 592 F.2d 1118, 1125 (10th Cir. 1979)); M.M. v. Zavaras, 139 F.3d 798, 803 (10th Cir. 1998) (internal quotation marks omitted) (the court’s decision to allow a pseudonym is based on “informed discretion, after taking all relevant factors into consideration”). 13 Femedeer, 227 F.3d at 1246. 14 Zavaras, 139 F.3d at 803 (internal quotation omitted); Weber State University, at *6 (citing Gibbs, 886 F.2d at 1245). 15 W.N.J. v. Yocum, 257 F.3d 1171, 1172 (10th Cir. 2001). 16 Id. DISCUSSION 1. The Court Grants Plaintiffs’ Stipulated Motion to Proceed Anonymously The court grants Plaintiffs’ stipulated motion to proceed anonymously because this case implicates “exceptional circumstances” that the Tenth Circuit and Rule 5.2 recognize as

warranting anonymity. First, most of the medial records and treatment at issue in this case refer to J.H.’s struggles as a minor, before the age of 18. Federal Rule of Civil Procedure 5.2(a)(3) requires litigants to protect the identity of minors by, at a minimum, only using the minor’s initials when filing their pleadings. Although J.H. is no longer under the age of 18, most jurisdictions recognize the appropriateness of preventing the names of children from disclosure past the date they reach majority, particularly where they may be burdened in adulthood by their earlier actions. The fact that J.H. was under the age of 18 during the treatment at issue in this case controls the court’s analysis, irrespective of J.H.’s age now.17 Because J.H. was under the age of 18 when undergoing treatment, the balance of interest favors protecting J.H.’s anonymity.

Further, while William H. is not a minor, disclosure of his full name would have the impact of

17 See e.g., Doe v. USD No. 237, 2017 U.S. Dist. LEXIS 142435 at *31 (D. Kan. 2017) (“[t]he fact that Doe was a minor at all times material to the allegations of the complaint is at the forefront of the Court’s analysis” when considering whether Plaintiffs should be allowed to proceed anonymously); see also N.E. v. Blue Cross Blue Shield Carolina, 2023 U.S. Dist. LEXIS 56537 at *49 (D.N.C. 2023) (In another ERISA case concerning mental health care, “although [plaintiff] is no longer a minor, [he] was a minor when the facts underlying this case occurred, which also weighs in favor of protecting his identity and by extension, [his parent’s] identity.”).

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Related

M.M. v. Zavaras
139 F.3d 798 (Tenth Circuit, 1998)
Femedeer v. Haun
227 F.3d 1244 (Tenth Circuit, 2000)
W.N.J. v. Yocom
257 F.3d 1171 (Tenth Circuit, 2001)
National Commodity And Barter Association v. Gibbs
886 F.2d 1240 (Tenth Circuit, 1989)

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