King v. Health Care Services Corp.

CourtDistrict Court, D. Montana
DecidedJune 11, 2025
Docket4:24-cv-00032
StatusUnknown

This text of King v. Health Care Services Corp. (King v. Health Care Services Corp.) is published on Counsel Stack Legal Research, covering District Court, D. Montana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
King v. Health Care Services Corp., (D. Mont. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA GREAT FALLS DIVISION

JUSTIN KING, CV-24-32-GF-BMM

Plaintiff,

vs. ORDER

HEALTH CARE SERVICES CORP.,

Defendant.

Plaintiff Justin King filed a motion for partial summary judgment on the basis that Defendant Health Care Services Corporation (“HCSC”), doing business as Blue Cross Blue Shield of Montana, had breached King’s insurance contract as a matter of law by denying coverage for King’s back surgery. (Doc. 55; Doc. 56.) HCSC filed a motion under Federal Rule of Civil Procedure 56(d) to deny King’s motion for summary judgment until HCSC develops discovery sufficient to respond. (Doc. 66.) HCSC reiterated these arguments in its response to King’s motion for summary judgment. (Doc. 75.) King responded. (Doc. 81.) The Court conducted a hearing on January 30, 2025. (Doc. 82.) 1 King moved for leave to file a Third Amended Complaint to add a claim under Montana’s Unfair Trade Practices Act (“UTPA”). (Doc. 89.) HCSC argued in

response that such an amendment would be futile. (Doc. 91.) HCSC also moved to vacate the Court’s scheduling order (Doc. 94), and King opposed. (Doc. 98.) I. FACTUAL BACKGROUND

King sought pre-approval from his insurer, HCSC, for a two-level lumbar disc arthroplasty with a Prodisc L artificial disc (the “back surgery”) in 2022. (Doc. 89, ¶ 7.) HCSC’s letter to King explained that it denied approval for the back surgery due to the “experimental” nature of the surgery under both the terms of King’s

Benefit Plan and those of the Medical Policy (SUR712.028). (Doc. 89 at 8.) The denial letter noted that “[p]er the Medical Policy, artificial intervertebral lumbar disc is considered experimental, investigational and/or unproven for multilevel use

whether done simultaneously or at different times.” (Id.) The letter explained that HCSC denied King’s claim because King’s Benefit Plan also excluded the back surgery as experimental. (Id.) The Benefit Plan defines a surgery as “experimental” when “the prevailing

opinion among peer reviewed medical and scientific literature regarding the procedure is that further studies or clinical trials are necessary to determine its safety, its efficacy or its efficacy as compared with a standard means of treatment or 2 diagnosis[,]” (the “prevailing opinion” definition). (Id.) King alleges that the Benefit Plan governs when a discrepancy exists between the Medical Policy and the

insured’s Benefit Plan. (Doc. 89, ¶ 9, fn. 1.) King’s policy requires HCSC to “tak[e] into consideration” a governmental or regulatory agency’s approval of a treatment, procedure, or device when assessing

whether it is experimental. (Doc. 89, ¶ 14.) The FDA approved the use of the Prodisc L device for the back surgery two years before HCSC denied King’s claim. (Id., ¶ 13.) HCSC’s did not “take into consideration” the FDA’s approval of the Prodisc L when it evaluated and denied King’s claim under the Benefit Plan. (Id., ¶

15.) King alleges that HCSC’s denial letter further misrepresented King’s policy coverage because the back surgery should not have been characterized as

experimental. (Id., ¶ 12.) Under the controlling Benefit Plan definition, King alleges that the “prevailing opinion among peer reviewed medical and scientific literature” regarding the back surgery concluded that no “further studies or clinical trials [were] necessary” to determine its safety or efficacy. (Id., ¶¶ 10–12.) King further alleges

that HCSC’s erroneous denial of coverage for the back surgery constitutes a breach of contract. (Id., ¶ 17.)

3 II. LEGAL STANDARD Summary judgment proves proper if the movant demonstrates “that there is

no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). The Court must view the evidence in the light most favorable to the non-moving party and draw all justifiable inferences in the

non-moving party’s favor. Anderson v. Liberty Lobby Inc., 477 U.S. 317, 323 (1986). A party may move to deny or defer ruling on summary judgment under Federal Rule of Civil Procedure 56(d) when “a nonmovant shows by affidavit or declaration that, for specified reasons, it cannot present facts essential to justify its opposition[.]”

Fed. R. Civ. P. 56(d). A party seeking relief under Rule 56(d) must show: “(1) it has set forth in affidavit form the specific facts it hopes to elicit from further discovery; (2) the facts sought exist; and (3) the sought-after facts are essential to oppose

summary judgment.” Family Home and Fin. Ctr., Inc. v. Fed. Home Loan Mortg. Corp., 525 F.3d 822, 827 (9th Cir. 2008). Courts grant leave to amend freely when justice so requires. Fed. R. Civ. P. 15(a)(2). “In deciding whether justice requires granting leave to amend, factors to

be considered include the presence or absence of undue delay, bad faith, dilatory motive, repeated failure to cure deficiencies by previous amendments, undue prejudice to the opposing party and futility of the proposed amendment.” Moore v. 4 Kayport Package Exp., Inc., 885 F.2d 531, 538 (9th Cir. 1989). Amendment would be futile when the proposed amendment renders the claim subject to dismissal.

Moore, 885 F.2d at 538; Scott v. Eversole Mortuary, 522 F.2d 1110, 1116 (9th Cir. 1975). III. DISCUSSION

King has moved the Court for leave to amend his complaint to add a misrepresentation claim under Montana’s UTPA and for summary judgment on his breach of contract claim. Both claims arise from HCSC’s denial of coverage for King’s back surgery as “experimental.” King argues that HCSC should have

covered the surgery because it was not “experimental,” and that HCSC’s denial letter on that basis thus constitutes a misrepresentation of his policy’s coverage. The Court will address each motion in turn.

A. King’s Motion for Leave to Amend King moved to amend his complaint because the previous Montana UTPA claim alleged an error on the part of the IER, rather than related to the actions of HCSC. (Doc. 90 at 1.) The proposed Third Amended Complaint remedies the error

by alleging that HCSC misrepresented King’s policy coverage by denying the back surgery as “experimental.” (Doc. 90 at 2.) King alleges also that HCSC failed to “take into consideration” the FDA’s approval of the Prodisc L as required by King’s 5 policy. HCSC’s denial of King’s claim as “experimental,” without taking into consideration the FDA’s approval and the prevailing opinion among recent peer-

reviewed medical and scientific literature, constitutes a misrepresentation as to coverage. (Id.) HCSC argues that amendment would be futile. (Doc. 91 at 2.) HCSC first responds that its failure to consider the FDA approval does not

constitute a misrepresentation and that HCSC properly relied on the Medical Plan definition of “experimental” to deny King’s claim. (Doc.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
King v. Health Care Services Corp., Counsel Stack Legal Research, https://law.counselstack.com/opinion/king-v-health-care-services-corp-mtd-2025.