In Re Bright Health Management, Inc. v. the State of Texas

CourtCourt of Appeals of Texas
DecidedJune 20, 2025
Docket15-25-00108-CV
StatusPublished

This text of In Re Bright Health Management, Inc. v. the State of Texas (In Re Bright Health Management, Inc. v. the State of Texas) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Bright Health Management, Inc. v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

ACCEPTED 15-25-00092-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 6/20/2025 5:16 PM NO. 15-25-00092-CV CHRISTOPHER A. PRINE CLERK IN THE COURT OF APPEALS FILED IN FOR THE FIFTEENTH JUDICIAL DISTRICT AUSTIN, TEXAS 15th COURT OF APPEALS

AUSTIN, TEXAS 6/20/2025 5:16:15 PM CHRISTOPHER A. PRINE Clerk IN RE BRIGHT HEALTH MANAGEMENT, INC., Appellant,

v.

BRIGHT HEALTH INSURANCE COMPANY OF TEXAS, Appellee.

On Appeal from the 455th Judicial District Court, Travis County, Texas Cause No. D-1-GN-23-008361 The Honorable Catherine Mauzy, Presiding

AND

NO. ____________

IN THE COURT OF APPEALS FOR THE FIFTEENTH JUDICIAL DISTRICT AUSTIN, TEXAS

IN RE BRIGHT HEALTH MANAGEMENT, INC.

Relator.

Original Proceeding Arising from the 455th Judicial District Court, Travis County, Texas Cause No. D-1-GN-23-008361 The Honorable Catherine Mauzy, Presiding BRIGHT HEALTH MANAGEMENT, INC.’S EMERGENCY MOTION FOR STAY OF DISTRICT COURT’S ORDER

Carlos Soltero csoltero@maynardnexsen.com State Bar No. 00791702 Brytne D. Kitchin bkitchin@maynardnexsen.com State Bar No. 24079973 Lisa Alcantar lalcantar@maynardnexsen.com State Bar No. 24069284 MAYNARD NEXSEN 2500 Bee Caves Road Bldg. 1, Suite 150 Austin, Texas 78746

Counsel for Appellant/Relator

2 TO THE HONORABLE FIFTEENTH COURT OF APPEALS:

Appellant/Relator Bright Health Management, Inc. (“BHM”)

respectfully files this Emergency Motion for Stay of District Court’s

Order (attached to this Motion as Exhibit 1) pursuant to Texas Rule of

Appellate Procedure 29.3 or, in the alternative, 52.10. BHM asks this

Court to stay the proceedings in the District Court as outlined below to

preserve this Court’s ability to rule on BHM’s interlocutory appeal or, in

the alternative, petition for writ of mandamus. BHM filed its Notice of

Appeal on May 16, 2025.

INTRODUCTION

On May 6, 2025, the Honorable Catherine Mauzy, presiding in the

455th Judicial District Court, Travis County, signed an Order Granting

Special Deputy Receiver’s Motion to Confirm Special Master’s

Recommendation and for Entry of Order Granting the Motion to Enforce

Permanent Injunction Against Bright Health Management, Inc. (the

“Order”), compelling BHM to produce business records it held and

maintained on behalf of Bright Health Insurance Company of Texas, Inc.

(“BHICOT”), a Texas-domiciled insurance company in receivership, and

denying BHM’s Cross-Motion for Entry of Order Governing

3 Electronically Stored Information (the “ESI Motion”). The appellee/real

party in interest is BHICOT.

The Order arose after the Special Deputy Receiver of BHICOT (the

“SDR”) demanded that BHM turn over all BHICOT-related emails of

BHICOT’s officers and directors and all BHM employees. BHM operates

as a shared-services entity, providing management and administrative

services to all its insurance company subsidiaries pursuant to separate

management services agreements.1 The suite of services offered by BHM

includes providing BHM employees to serve as officers and/or directors

of an insurance company client as well as “claims administration,

accounting, legal services, financial services, actuarial services.

Effectively everything.” 2

BHM employees, like the employees of most management

companies that are part of a large holding company structure, have a

single email address. Thus, simply providing the SDR with all emails of

the BHM employees who served as officers and directors of BHICOT or

1 Indeed, prior to commencement of the receivership, BHM and BHICOT entered into

a Management Services Agreement (the “MSA”), under which BHM agreed to manage the day-to-day operations of BHICOT’s Texas-based health insurance business, including maintenance of BHICOT’s books and records. 2 3 RR 762, p. 162:24–163:7.

4 provided other services to BHICOT would result in the SDR receiving

thousands of emails and other documents wholly unrelated to BHICOT.3

Worse, these irrelevant documents and emails contain information about

the affiliates to whom BHM also provides management services,

including protected health information relating to medical clinics

operated by BHM’s affiliate, NeueHealth, Inc., and its subsidiaries

(collectively, “NeueHealth”). Further compounding the problem is the

inclusion of attorneys among the relevant custodians, whose roles include

serving in the capacity of general in-house counsel, providing legal advice

to affiliated entities on myriad subjects unrelated to BHICOT.

To maintain the confidentiality of the information in BHM’s

possession that is unrelated to BHICOT, BHM proposed coordinating

efforts to identify key search terms and queries to address any legitimate

interest the SDR, on behalf of BHICOT, may have in the emails. Initially,

the SDR agreed to have, “the respective IT professionals work together

to agree on key search terms and queries,” and agreed to provide

proposed terms and queries. However, the SDR later withdrew this

3 For example, the initial data pull of the BHM employees who served as BHICOT’s

officers and directors produced roughly 600,000 emails, much of which was unrelated to BHICOT.

5 agreement to collaborate, now stating it, “did not intend to limit BHM’s

obligation to produce BHICOT’s business records,” and that, “[t]he search

parameters should be all records that mention, refer to or relate to

BHICOT.”

Having reached an impasse, the SDR filed a Motion to Enforce

Injunction Against BHM to compel production of BHICOT’s business

records, and BHM filed the ESI Motion, arguing the SDR has no blanket

right to examine all BHM records without regard to whether they are

BHICOT records. However, the District Court’s Order effectively

requires BHM to do just that, with a status report due to the District

Court by May 26, 2025, and every 20 days thereafter, and all documents

produced by August 4, 2025. Therefore, BHM seeks immediate protection

from the Order to preserve this Court’s ability to rule on BHM’s

interlocutory appeal or, in the alternative, petition for writ of mandamus

(the “Appeal”).

ARGUMENT

Pursuant to Texas Rule of Appellate Procedure 29.3 or, in the

alternative, 52.10, this Court has the authority to grant a stay to preserve

an appellant’s or relator’s rights, respectively, until disposition of an

6 appeal or writ of petition for mandamus. TEX. R. APP. P. 29.3 & 52.10(b).

Here, an immediate stay of the Order is necessary to preserve BHM’s

rights pending disposition of its Appeal.

The Order effectively requires BHM to provide the SDR with

confidential and potentially highly sensitive NeueHealth information

that is wholly unrelated to BHICOT, including privileged and HIPAA-

protected materials, and to which the SDR is not entitled to under the

MSA or any law. BHM understands that the SDR’s request is not exactly

a traditional “discovery request,” as it relates to seeking the books and

records of an insurance company in receivership. But, absent any

statutory requirements or other applicable guidelines for production of

documents in an insurance company receivership, BHM contends that

Texas’ well-established ESI principles cannot be simply ignored. Even if

the ESI jurisprudence of In re Weekly Homes and other authorities may

not be completely controlling legal precedent, they are not irrelevant to

this legal inquiry and at a minimum are highly instructive.

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In Re Weekley Homes, L.P.
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Bluebook (online)
In Re Bright Health Management, Inc. v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-bright-health-management-inc-v-the-state-of-texas-texapp-2025.