Healthcare Justice Coalition DE Corp. v. Cigna Health and Life Insurance Co.

CourtDistrict Court, D. Connecticut
DecidedMay 15, 2025
Docket3:23-cv-01689
StatusUnknown

This text of Healthcare Justice Coalition DE Corp. v. Cigna Health and Life Insurance Co. (Healthcare Justice Coalition DE Corp. v. Cigna Health and Life Insurance Co.) is published on Counsel Stack Legal Research, covering District Court, D. Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Healthcare Justice Coalition DE Corp. v. Cigna Health and Life Insurance Co., (D. Conn. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

HEALTHCARE JUSTICE COALITION DE CORP., Plaintiff,

v. No. 3:23-cv-01689 (KAD)

CIGNA HEALTH AND LIFE INSURANCE CO. and CIGNA HEALTHCARE OF CONNECTICUT, INC. Defendants.

MEMORANDUM OF DECISION RE: [62] MOTION TO DISMISS

Kari A. Dooley, United States District Judge Plaintiff Healthcare Justice Coalition DE Corp. (“HJC”)—the assignee of claims from NES Medical Services of Northern Connecticut (“NES”), an emergency physician group—sues Defendants Cigna Health and Life Insurance Co. and Cigna Healthcare of Connecticut, Inc. (together, “Cigna”) for alleged failure to pay for emergency medical services rendered to Cigna members by NES. HJC asserts claims under the Connecticut Unfair Trade Practices Act (“CUTPA”), premised on violations of the Connecticut Unfair Insurance Practices Act (“CUIPA”) and the Connecticut Surprise Billing Law (“SBL”); and for unjust enrichment, quantum meruit, and declaratory relief. The Court (Meyer, J.)1 previously granted Cigna’s motion to dismiss without prejudice after which HJC filed an amended complaint. Cigna has again filed a motion to dismiss. For the reasons set forth below, the motion to dismiss is GRANTED. ALLEGATIONS

1 This matter was transferred to the undersigned on January 17, 2025. HJC is a debt collector—specifically, it is a corporate entity that acquires rights to pursue unpaid or underpaid insurance claims from healthcare providers. See Doc. #59 at 1 (¶ 1). Once it obtains reimbursement rights from emergency medicine practice groups, it then seeks to collect on those rights from insurance companies like Cigna. Id. HJC purchased reimbursement claims

from NES, a group of emergency medicine physicians providing services at Day Kimball Hospital and Johnson Memorial Hospital. Id. at 3 (¶ 10). NES did not have a contract with Cigna during the period covered by the complaint. Id. at 6 (¶ 20). Some of NES’s patients had insurance through Cigna, but NES’s services were out-of-network. Id. at 6 (¶¶ 18-19). Despite being out-of-network, Cigna was obligated to pay NES under the terms of Connecticut’s SBL. See Doc. #59 at 4 (¶ 12); see generally Conn. Gen. Stat. § 38a-477aa. The SBL requires insurance companies like Cigna to pay a statutorily specified rate for emergency services, which is the greatest of (i) the fee that the company would pay for in-network emergency services; (ii) “the usual, customary and reasonable rate as set forth in the FAIR Health database;” or (iii) the Medicare Rate. See Conn. Gen. Stat. § 38a-477aa(b)(3)(A).

HJC claims that Cigna has failed to pay the rates NES billed or the rates required by the SBL. Id. at 6-7 (¶ 21).2 And it insists Cigna has underpaid some claims and outright failed to pay others. See, e.g., id. at 6-7 (¶¶ 21-22). As a result, HJC maintains Cigna has avoided some $5.3 million in payments. See, e.g., id. at 19 (¶ 63).3 HJC’s original complaint contained few details. See generally Doc. #1. For example, it did not specify the period during which Cigna had allegedly failed to pay, the types of claims

2 HJC does not clearly state whether the amount NES billed—“the reasonable value of [its] emergency medical services”—is the same or greater than the SBL rate. See Doc. #59 at 18 (¶ 59). Instead, HJC says only that the “reasonable value” is consistent with SBL obligations. See id. at 13-14 (¶ 43(a)). 3 The Court notes that the original complaint stated that Cigna had avoided some $3.5 million in payments. See Doc. #1 at 10 (¶ 48). At oral argument, HJC explained that in the period after the original complaint was filed and oral argument, it had continued to finalize its purchase of additional debt from NES, hence the increased amount. that were underpaid, the amount NES billed for its services, any amounts Cigna has paid, the number of claims that have been underpaid, or any explanation Cigna provided for failing to pay. Nevertheless, HJC brought a claim under the Connecticut Unfair Trade Practices Act (CUTPA), as well as claims for unjust enrichment, quantum meruit, and seeking damages and declaratory

relief. Cigna moved to dismiss on a variety of grounds, including Rule 8 of the Federal Rules of Civil Procedure. See Doc. #23. The Court granted the motion to dismiss on Rule 8 grounds, without prejudice to HJC’s filing of an amended complaint. See Doc. #57. HJC has done so—and it includes some more detail, examples, and illustrations of the nature of its claims, and appends an exhibit consisting of a lengthy table of healthcare claims and the dates of service for said claims. See generally Doc. #59; Doc. #59-1. Cigna has moved to dismiss the amended complaint. See Doc. #63. It argues that each count of the complaint fails to state a claim for relief and that, moreover, the Employee Retirement Income Security Act of 1974 (“ERISA”) preempts all of HJC’s claims. STANDARD OF REVIEW

It is well established that to survive a motion to dismiss filed pursuant to Rule 12(b)(6), “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678. This “plausibility” requirement is “not akin to a probability requirement,” but it “asks for more than a sheer possibility that a defendant has acted unlawfully.” Iqbal, 556 U.S. at 678; Charles v. Orange Cnty., 925 F.3d 73, 81 (2d Cir. 2019) (same). In addition, a court is “not bound to accept as true a legal conclusion couched as a factual allegation” or “to accept as true allegations that are wholly conclusory.” Krys v. Pigott, 749 F.3d 117, 128 (2d Cir. 2014). DISCUSSION

ERISA Preemption The Court first addresses the issue of ERISA preemption. ERISA is a comprehensive federal statute designed to regulate employee benefit plans, including employer-sponsored health insurance. Among other things, ERISA sets minimum standards for plan administration and fiduciary duties, and it broadly preempts state laws that “relate to” such plans to ensure uniform national regulation. 29 U.S.C. § 1144(a).4 “ERISA pre-empts ‘any and all State laws insofar as they may now or hereafter relate to any employee benefit plan’ covered by ERISA.” Rutledge v. Pharm. Care Mgmt. Ass’n, 592 U.S. 80, 85 (2020) (quoting 29 U.S.C. § 1144(a)). “‘A state law relates to an ERISA plan if it has a connection with or reference to such a plan.’” Id. (quoting Egelhoff v. Egelhoff, 532 U.S. 141,

147 (2001)).

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Healthcare Justice Coalition DE Corp. v. Cigna Health and Life Insurance Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/healthcare-justice-coalition-de-corp-v-cigna-health-and-life-insurance-ctd-2025.