La Frontera Center v. United Behavioral Health

Court of Appeals for the Tenth Circuit·Decided August 26, 2026·No. 25-2099·Unpublished

Opinion

FILED

United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT August 26, 2026

Christopher M. Wolpert

Clerk of Court

UNITED STATES OF AMERICA and THE STATE OF NEW MEXICO, ex rel. LA FRONTERA CENTER, INC., an Arizona nonprofit corporation, relator,

Plaintiff - Appellant,

v. No. 25-2099 (D.C. No. 1:15-CV-01164-KWR-JMR)

UNITED BEHAVIORAL HEALTH, INC., (D. N.M.) a foreign corporation; UNITED HEALTHCARE INSURANCE, INC., a foreign corporation; OPTUMHEALTH NEW MEXICO, operating as a d/b/a of United Behavioral Health, Inc.; UNITED HEALTHCARE INS. CO.; BLACK AND WHITE CORPORATIONS; JOHN AND JANE DOES I-X,

Defendants - Appellees.

ORDER AND JUDGMENT *

Before HOLMES, Chief Judge, McHUGH, and CARSON, Circuit Judges.

Relator La Frontera Center, Inc., filed this qui tam action alleging that Defendants violated the United States’ False Claims Act (“FCA”), New Mexico’s Fraud Against Taxpayers Act (“FATA”), New Mexico’s Medicaid False Claims Act

*

This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1.

(“MFCA”), and New Mexico’s Medicaid Fraud Act (“MFA”). The district court dismissed the MFCA and MFA claims, along with one FCA claim. The district court later granted summary judgment to Defendants on the remaining claims because Relator failed to point to sufficient evidence in the record to demonstrate a triable issue of fact as to whether Defendants acted “knowingly” in violation of the law. Relator appealed. Exercising jurisdiction under 28 U.S.C. § 1291, we affirm.

I.

In 2008, the State of New Mexico sought out an entity to manage its statewide behavioral health services. The State of New Mexico Interagency Behavioral Health Purchasing Collaborative (“Collaborative”) issued a Request for Proposal (“RFP”) seeking such entity to manage “all covered behavioral health services,” which included administrative and system development, managing and coordinating services funded primarily by Medicaid, and adjudicating and paying “clean claims” from providers who were not “under investigation for fraud and abuse.”

United submitted a 1024-page response to the RFP detailing its qualifications for the position. To prepare the Response, United tasked a team with “significant experience in designing claims systems” who “conducted extensive due diligence” while preparing the Response. This team focused the Response on United’s “anticipated approach to patient care and provider satisfaction, along with its technical qualifications and proposed claims system.” United reported relevant and substantial prior experience implementing similar programs in other states, including experience designing and implementing programs meant to detect fraud, waste, and

abuse (“FWA”). United accurately represented its FWA experience and credentials. The persons drafting the response had first-hand knowledge of United’s credentials and experience and were not aware of any false or misleading statements related to United’s qualifications and experience. No one involved in preparing the Response raised concerns about its representations.

The Collaborative awarded United the Collaborative’s Behavioral Health Services Contract (“Contract”). The Contract made United “the sole Medicaid and non-Medicaid Managed Care Organization (“MCO”) responsible for coordinating delivery of government-funded behavioral health services in New Mexico.” The Contract required United to, among other things, “manage, track, and report the use of funds for the provision of behavioral health services, as directed by the Collaborative.”

To prepare to perform under the Contract, United “developed a claims adjudication system specifically for New Mexico’s funding requirements.” The Collaborative administered multiple rounds of readiness reviews of United’s adjudication system before launch and found no concerns or issues with its functionality. On the first day of the Contract term, “United launched a functioning claims processing system.” Three months later, the Collaborative’s CEO informed the New Mexico Legislature that United routinely met all Contract requirements. She also reported that the New Mexico Medical Review Association’s audit gave United “a compliance score of 84%” and perfect “Reimbursement” and “Reporting Requirements” scores.

But United began to experience problems performing the Contract. So the Collaborative issued a sanctions letter alleging that United breached the Contract. Although United disputed the allegations, it negotiated a Directed Corrective Action Plan (“DCAP”) with the Collaborative. Under the DCAP, United paid a civil penalty and agreed to the appointment of an independent monitor. After a few years, the monitor concluded that United “met the contractual and DCAP defined standards for claims timeliness, denial accuracy, and accounting” since the start of the DCAP. The Collaborative closed the DCAP in 2012.

Later in 2012, United noticed suspicious billing patterns and activity with fifteen New Mexico providers. Because the Contract required it to report activity indicating fraud or abuse, United reported its observations to the Collaborative. As a result, the New Mexico Human Services Department (“HSD”) hired a third-party auditor to review those fifteen providers’ claims for fraud and abuse. During the investigation, HSD suspended those providers and instructed United to withhold payments to them. United complied. A few years later, HSD directed United to release the withheld payments to those providers. United promptly complied.

During the fifteen providers’ suspension, the Collaborative designated five Arizona providers to fill the gap left in New Mexico’s behavioral health services. Relator was one of those five Arizona providers. But according to Relator, the claims processing system did not function appropriately, leaving Relator with millions of dollars of unpaid claims.

As a result, Relator filed this qui tam action, alleging five claims against Defendants under the FCA, FATA, MFCA, and MFA. 1 Defendants moved to dismiss Relator’s claims. The district court granted Defendants’ motion to dismiss Relator’s FCA claim (“Count I”) because the statute of limitations barred the claim and the public disclosure bar applied. It also dismissed Relator’s claims under the MFCA because HSD found no substantial evidence to support the claims. Finally, the district court dismissed Relator’s claim under the MFA, finding that Relator could not file a private action under the MFA. 2 The district court allowed Relator’s “reverse” FCA claim (“Count II”), “reverse” FATA claim (“Count III”), and FATA claim (“Count V”) to proceed.

Later, Defendants filed for summary judgment on Relator’s remaining claims.

The district court determined that Relator failed to set forth specific facts from which a rational trier of fact could find for Relator on any of its remaining claims. Under Counts II and III—the “reverse” false claims—Relator argued that United knowingly failed to timely fulfill an obligation to pay the State money. The district court found that (1) “the record d[id] not establish that [Defendants] owed an obligation to pay funds to the State at the time the alleged violation occurred,” and (2) “even if [Defendants] owed an obligation to pay funds to the State, the record lack[ed]

1 Relator filed this suit under seal as 31 U.S.C. § 3730(b) requires. In 2022, the United States and the State of New Mexico declined to intervene, allowing Relator to move forward with the case. See § 3730(b).

2 Relator does not appeal the dismissal of its MFCA or MFA claims.

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