Hospital Quirurgica Del Sur v. Martin's Point Health Care, Inc.

CourtCourt of Appeals for the First Circuit
DecidedAugust 19, 2025
Docket24-1816
StatusPublished

This text of Hospital Quirurgica Del Sur v. Martin's Point Health Care, Inc. (Hospital Quirurgica Del Sur v. Martin's Point Health Care, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hospital Quirurgica Del Sur v. Martin's Point Health Care, Inc., (1st Cir. 2025).

Opinion

United States Court of Appeals For the First Circuit

No. 24-1815

HOSPITAL AMERIMED CANCUN S A DE C V,

Plaintiff, Appellant,

v.

MARTIN'S POINT HEALTH CARE, INC.,

Defendant, Appellee.

No. 24-1816

HOSPITAL QUIRURGICA DEL SUR,

APPEALS FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MAINE

[Hon. Lance E. Walker, U.S. District Judge]

Before

Montecalvo, Kayatta, and Aframe, Circuit Judges.

Mark A. Darling, with whom Litchfield Cavo, LLP was on brief, for appellants. Brian P. Dunphy, with whom Nicole L. Masiello, Alexis P. Gannaway, Alex E. Sirio, and Arnold & Porter Kaye Scholer LLP were on brief, for appellee.

August 19, 2025 AFRAME, Circuit Judge. These consolidated appeals

challenge the dismissals of two diversity actions brought by

hospitals incorporated and operating in Mexico (together, the

"Hospitals") against Martin's Point Health Care, Inc. ("Martin's

Point"), a Maine health insurance company. The district court

dismissed both actions for lack of subject-matter jurisdiction,

concluding that the Hospitals' negligent-misrepresentation and

promissory-estoppel claims arose under the Medicare Act, such that

the Hospitals were required to exhaust administrative remedies

before suing Martin's Point in federal court. See 42 U.S.C.

§§ 405(g)-(h), 1395w-22(g)(5), 1395ii. On appeal, the Hospitals

contend that they were not required to exhaust administrative

remedies because their claims do not arise under the Medicare Act.

Alternatively, they argue that they should have been exempted from

the exhaustion requirement because, as foreign hospitals, they

cannot participate in Medicare's administrative-remedies process.

We affirm.

I.

The facts and procedural history of the two appeals are

similar.1 Each began with a Martin's Point enrollee seeking

1 We draw the facts from the Hospitals' complaints and extrinsic material considered by the district court. See Aversa v. United States, 99 F.3d 1200, 1209-10 (1st Cir. 1996). The extrinsic material considered was certain correspondence from Martin's Point, as well as benefits-verification forms completed

- 3 - medical care from one of the plaintiff hospitals while in Mexico.

Upon admission, the enrollees signed contracts obligating them to

pay for all services rendered by the admitting hospital. They

also provided information about their Martin's Point medical

insurance. The Hospitals then each contacted Martin's Point

through the same third-party administrator. Martin's Point

allegedly represented to the administrator that the enrollees had

"full medical insurance benefits for the . . . out of country

emergency services proposed to be provided." The administrator

thereafter created verification-of-benefits forms stating that the

enrollees' benefits were "unlimited."

Believing that the enrollees had "unlimited" benefits,

the Hospitals provided them with extensive medical treatment.

Partway through the enrollees' hospital stays, Martin's Point sent

letters authorizing the stays for several days. The letters

stated, however, that Martin's Point's authorization was "subject

to Medicare coding requirements for coverage" and that "payment

[wa]s based on the [enrollee's] eligibility and benefit coverage

at the time of service." When the Hospitals discharged the

enrollees, the enrollees had incurred medical bills of

$2,132,982.98 and $512,464.00, respectively. The Hospitals sought

by a third-party administrator used by the Hospitals. No one contends on appeal that the court's consideration of these documents was improper.

- 4 - reimbursement from Martin's Point, but Martin's Point, asserting

that the two enrollees' Medicare Advantage plans capped benefits

for out-of-country medical services at $25,000, refused to

reimburse the Hospitals above that limit.

The Hospitals then commenced separate civil actions in

the District of Maine against Martin's Point based on diversity

jurisdiction, 28 U.S.C. § 1332, asserting Maine common-law claims

for promissory estoppel and negligent misrepresentation (together,

the "common-law claims"). The Hospitals' common-law claims rested

on the same premise: By misrepresenting to the third-party

administrator that its enrollees' medical insurance would fully

cover the proposed course of treatment, Martin's Point had induced

the Hospitals to provide non-reimbursable care to the enrollees.

Martin's Point moved to dismiss, arguing that the

Hospitals' common-law claims sought, at bottom, reimbursement

under the enrollees' Medicare Advantage plans. And Martin's Point

submitted that, because the Hospitals had not administratively

exhausted their benefits claims under the Medicare Act, the

district court lacked subject-matter jurisdiction over the

actions. See Fed. R. Civ. P. 12(b)(1). Martin's Point also argued

that the Hospitals' common-law claims failed to state claims for

relief even if they were not construed as Medicare-benefits claims.

See Fed. R. Civ. P. 12(b)(6). The Hospitals opposed the motions,

insisting that because they provided care outside the United States

- 5 - and sought recovery on common-law theories, they were not required

to exhaust their claims through Medicare's appeals process. The

Hospitals also argued that their complaints plausibly alleged

common-law claims for relief.

In substantially identical memorandum opinions, the

district court granted Martin's Point's motions to dismiss for

lack of subject-matter jurisdiction. See Hosp. Amerimed Cancun

S A de C V v. Martin's Point Health Care, Inc., No. 23-cv-00258,

2024 WL 1769171 (D. Me. Apr. 23, 2024) [hereinafter Amerimed I];

Hosp. Quirurgica Del Sur v. Martin's Point Health Care, Inc., No.

23-cv-00259, 2024 WL 1769183 (D. Me. Apr. 23, 2024) [hereinafter

Quirurgica I]. The court first described the general

administrative-exhaustion requirements for claims arising under

Medicare. Amerimed I, 2024 WL 1769171, at *3-4; Quirurgica I,

2024 WL 1769183, at *3-4. Then, turning to the Hospitals' claims,

the court concluded that, despite being styled as common-law causes

of action, the claims sought to make Martin's Point "pay for

services provided to . . . Medicare Part C enrollee[s]" and

therefore arose under Medicare. Amerimed I, 2024 WL 1769171, at

*5; Quirurgica I, 2024 WL 1769183, at *5. Because the Hospitals

had not exhausted their administrative remedies under Medicare

Part C before filing suit in federal district court, the court

granted Martin's Point's motions and entered judgment dismissing

- 6 - each case. See Amerimed I, 2024 WL 1769171, at *5; Quirurgica I,

2024 WL 1769183, at *5.

The Hospitals subsequently moved to alter the judgments

of dismissal, arguing that, as foreign hospitals, they could not

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