Kenai Drilling Limited v. Sun Life Assurance Company of Canada

CourtDistrict Court, D. Nevada
DecidedJanuary 21, 2025
Docket2:24-cv-01559
StatusUnknown

This text of Kenai Drilling Limited v. Sun Life Assurance Company of Canada (Kenai Drilling Limited v. Sun Life Assurance Company of Canada) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kenai Drilling Limited v. Sun Life Assurance Company of Canada, (D. Nev. 2025).

Opinion

1 UNITED STATES DISTRICT COURT

2 DISTRICT OF NEVADA

3 * * *

4 KENAI DRILLING LIMITED, a Case No. 2:24-cv-01559-CDS-EJY Delaware Corporation, and KENAI 5 DRILLING LIMITED EMPLOYEE BENEFIT PLAN, ORDER 6 Plaintiffs, 7 AND v. 8 REPORT AND RECOMMENDATION SUN LIFE ASSURANCE COMPANY OF 9 CANADA,

10 Defendant.

11 12 Pending before the Court is Plaintiffs Kenai Drilling Limited and Kenai Drilling Limited 13 Employee Benefit Plan’s Petition to Compel Arbitration (ECF No. 1-2). Also pending are Plaintiffs’ 14 Motion for Leave to Supplement this Petition (ECF No. 28) and Motion for Leave to File an 15 Amended Complaint (ECF No. 27). The Court has considered Plaintiffs’ Petition and Motions, 16 Defendant’s Response to the Petition (ECF No. 13), and Plaintiffs’ Reply (ECF No. 26). 17 I. Background 18 This case arrives before the Court in the form of a Petition to Compel Arbitration originally 19 filed in state court. ECF No. 1-2. The underlying dispute involves an alleged underpayment by 20 Kenai Drilling Limited (“Kenai”) and Kenai Drilling Limited Employee Benefit Plan (the “Kenai 21 Plan”) to non-party Sunrise Hospital and Medical Center (“Sunrise”) on a claim made for services 22 provided to a plan participant. Id. at 3-4. Through an arrangement between the Kenai Plan’s third- 23 party administrator, Hawaii Mainland Administrators (“HMA”), and Connecticut General Life 24 Insurance Company (“Cigna”), the Kenai Plan had access to discounted rates that were negotiated 25 between Cigna and various healthcare providers, including Sunrise. ECF No. 13 at 3. The contract 26 between Cigna and Sunrise, the Hospital Services Agreement (“HSA”), is the agreement under 27 which both the underlying dispute and the instant Petition arise. 1 In addition to the agreement with Cigna, the Kenai Plan has a stop-loss insurance policy (the 2 “Policy”) with Sun Life Assurance Company of Canada (“Sun Life”), the Defendant in the instant 3 action. In sum, the Policy provides that Sun Life will reimburse the Kenai Plan for all eligible 4 expenses incurred by a plan participant that exceed $45,000. ECF No. 1-2 at 173, 176. 5 Section II.A.9 of the HSA, to which Sun Life is not a party, states the Kenai Plan, as a 6 contracted payor, is required “to pay in accordance with and abide by the financial terms” of the 7 HSA. Id. at 19, 30. Section III.O.3 of the HSA states that all “[d]isputes regarding [Sunrise]’s 8 payment or termination … and any other dispute between the parties regarding the performance or 9 interpretation of the [HSA] shall be resolved by arbitration.” Id. at 142-43. 10 Between February 17 and September 30, 2022, Sunrise provided care to Baby K.T. Sunrise 11 represents that each of the services provided were pre-certified and priced by Cigna according to the 12 HSA. Id. at 20. The total amount billed to the Kenai Plan, after applying the discounted rates under 13 the HSA, was $9,371,609.39. Id. at 22. Based on representations by the parties, it appears only a 14 fraction of this amount was actually paid. ECF No. 13 at 5; ECF No. 26 at 3. 15 After satisfying all conditions precedent, Sunrise initiated arbitration proceedings under 16 Section III.O.3 of the HSA against Plaintiffs, HMA, and Cigna claiming damages in the amount of 17 the underpayment. ECF No. 1-2 at 19. Plaintiffs in this action, as defendants in the underlying 18 arbitration proceeding, included in their responsive pleading third-party complaints against HMA 19 and Sun Life seeking contractual and equitable indemnification from each. Id. at 74. It appears 20 from the record before the Court that although HMA responded and made an appearance in the 21 arbitration proceedings, Sun Life did not. Because of this, Plaintiffs filed the instant Petition to 22 Compel Arbitration against Sun Life in state court on July 24, 2024, citing NRS Chapter 38 and the 23 Federal Arbitration Act (“FAA”) as bases. Id. at 2-3. Sun Life timely removed to federal court on 24 August 23, 2024. ECF No. 1. After Sun Life had filed its brief in opposition to the Petition to 25 Compel Arbitration, Plaintiffs included with their Reply a Motion for Leave to File an Amended 26 Complaint should the Court deny their Petition. ECF No. 27. 27 1 II. The Parties’ Arguments 2 Sun Life is not a party to the HSA. This is undisputed. Nonetheless, Plaintiffs assert two 3 theories under which they believe Sun Life is subject to the HSA’s arbitration provision. First, 4 Plaintiffs argue that Sun Life is a third-party beneficiary to the HSA supported by the proposition 5 that third-party beneficiary status can bind a non-signatory to an agreement to arbitrate. ECF No. 1- 6 2 at 7 citing Truck Ins. Exch. v. Palmer J. Swanson, Inc., 189 P.3d 656 (Nev. 2008), and Comer v. 7 Micor, Inc., 436 F.3d 1098 (9th Cir. 2006). Second, Plaintiffs argue that Sun Life is barred from 8 avoiding the HSA’s arbitration provision under the doctrine of equitable estoppel. ECF No. 1-2 at 9 10-11; ECF No. 26 at 10-11 citing Truck Ins. Exch. and RUAG Ammotec GmbH v. Archon Firearms, 10 Inc., 538 P.3d 428 (Nev. 2023).1 11 According to Plaintiffs, Sun Life is a third-party beneficiary of the HSA because Sun Life 12 received the same discounted rates under that agreement as the Kenai Plan. ECF No. 1-2 at 9. In 13 Plaintiffs’ view, this demonstrates that “the HSA clearly intended” to benefit Sun Life despite Sun 14 Life not being a signatory to the agreement. Id.at 10. To support their argument, Plaintiffs point to 15 provisions of the Policy stating Sun Life would not reimburse the Plan for “[a]ny amount paid … in 16 excess of a negotiated provider discount,” and requiring Plaintiffs to provide a “discount amount” 17 for any expenses submitted as part of a claim under that Policy. Id. Plaintiffs offer this as evidence 18 that Sun Life was aware of the discounted rates under the HSA and benefitted from them. Id. at 10- 19 11. 20 Plaintiffs’ alternative argument in favor of equitable estoppel treads much the same ground. 21 Citing to the portion of the Truck Ins. Exch. opinion stating that “a nonsignatory is estopped from 22 refusing to comply with an arbitration clause when it receives a direct benefit from a contract 23 containing an arbitration clause,” 189 P.3d at 661 (internal quotations omitted), Plaintiffs argue Sun 24 Life “directly benefitted from the discounted rates” of the HSA and therefore cannot avoid that 25

1 Plaintiffs also argue at various times that Sun Life is a third-party beneficiary of the HSA by virtue of acting as 26 Plaintiffs’ agent. ECF No. 1-2 at 11. Although agency is a separate theory under which a non-signatory may be bound by a contract, Plaintiffs present no independent agency argument in their initial moving papers and instead include it as 27 part of their third-party beneficiary argument. Id. In their Motion for Leave to Supplement, Plaintiffs separate agency 1 agreement’s arbitration provision. ECF No. 1-2 at 11. Separate from this theory, Plaintiffs argue 2 for the first time in their Reply that Sun Life also benefited from the HSA by utilizing the 3 agreement’s audit provision to initiate a third-party audit of the underlying claim, citing to additional 4 evidence suggesting that the alleged underpayment was the result of an audit performed at Sun Life’s 5 request. ECF No. 26 at 3-5, 10. 6 In its Response, Sun Life argues that Plaintiffs’ Petition is mistaken as to the facts and law. 7 First, Sun Life asserts that the Nevada Supreme Court has never held third-party beneficiary status 8 to be sufficient grounds to compel a non-signatory to arbitrate. As Sun Life points out, although 9 Plaintiffs list “third party beneficiary” as a sixth basis on which Truck Ins. Exch.

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Kenai Drilling Limited v. Sun Life Assurance Company of Canada, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kenai-drilling-limited-v-sun-life-assurance-company-of-canada-nvd-2025.