McNeal v. The Hartford Insurance Company

CourtDistrict Court, S.D. New York
DecidedJuly 21, 2025
Docket1:24-cv-07448
StatusUnknown

This text of McNeal v. The Hartford Insurance Company (McNeal v. The Hartford Insurance Company) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McNeal v. The Hartford Insurance Company, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK DAVID JOSEPH MCNEAL, Plaintiff, 24-CV-7448 (KMW) -against- ORDER OF DISMISSAL THE HARTFORD; GERARD DEGREGORIS WITH LEAVE TO REPLEAD III, MD; AETNA INC., Defendants. KIMBA M. WOOD, United States District Judge: Plaintiff David Joseph McNeal, who resides in New York and appears pro se, brings this action against his New York City doctor, Gerard Degregoris (“Degregoris”), and two insurance companies, The Hartford (“Hartford”) and Aetna, Inc. (“Aetna”), both citizens of Connecticut.1 By Order dated October 7, 2024, the Court granted Plaintiff’s request to proceed in forma pauperis (“IFP”), that is, without prepayment of fees. (ECF No. 5.) For the reasons set forth below, the Court dismisses this action for lack of subject matter jurisdiction, and grants Plaintiff 30 days’ leave to replead.

STANDARD OF REVIEW The Court must dismiss an IFP complaint, or any portion of the complaint, that is frivolous or malicious, fails to state a claim on which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B); see Livingston v. Adirondack Beverage Co., 141 F.3d 434, 437 (2d Cir. 1998). The Court must also

1 Plaintiff filed his original complaint on September 30, 2024 (ECF No. 1) and an amended complaint on October 7, 2024 (ECF No. 6). dismiss a complaint when the Court lacks subject matter jurisdiction over the claims raised. See Fed. R. Civ. P. 12(h)(3). Although the law mandates dismissal on any of these grounds, the Court is obligated to construe pro se pleadings liberally, Harris v. Mills, 572 F.3d 66, 72 (2d Cir. 2009), and to

interpret them to raise the “strongest [claims] that they suggest,” Triestman v. Fed. Bureau of Prisons, 470 F.3d 471, 474-75 (2d Cir. 2006) (per curiam) (internal quotation marks and citations omitted) (emphasis in original). But the “special solicitude” courts provide to pro se litigants, id. at 475 (citation omitted), has its limits—to state a claim, pro se pleadings still must comply with Rule 8 of the Federal Rules of Civil Procedure, which requires a complaint to make a short and plain statement showing that the pleader is entitled to relief. Fed. R. Civ. P. 8(a)(2).

BACKGROUND This action concerns Plaintiff’s insurance coverage, his doctor’s alleged failure to complete necessary paperwork regarding that coverage, and Hartford’s termination of Plaintiff’s insurance. The action also concerns Hartford’s and Aetna’s alleged violation of the Health

Insurance Portability and Accountability Act (“HIPAA”). The following facts are drawn from the amended complaint.2 (ECF No. 6.) In June 2020, Hartford terminated Plaintiff’s “insurance claim and payments . . . based on alleged inconsistencies in [Plaintiff’s] condition.” (Id. at 5.) Both Hartford and Degregoris failed to complete necessary “compliance documentation,” causing the termination of Plaintiff’s claims. (Id.) Degregoris “failed to address [Plaintiff’s] work capacity in full . . . [and] was negligent in

2 The Court quotes from the amended complaint verbatim. All spelling, grammar, and punctuation appear as in the amended complaint, unless noted otherwise. [Plaintiff’s] care when he refused to give [Plaintiff] a spinal injection, prescription for continued care through therapy, and terminated [Plaintiff’s] care while [Plaintiff] was insured through Medicare, and [Degregoris] was a Medicare provider.” (Id. at 5-6.) Plaintiff also alleges that Hartford and Aetna “recklessly violated HIPAA when they

disclosed David McNair’s medical records.” (Id. at 6.) Plaintiff claims that “[t]hey were aware that a great number of Mr. McNairs medical records [were] in [Plaintiff’s] claim file . . . [and that] [o]n 6/30/22 those records were released to NYLAG Attorney Debra Wolf, along with [Plaintiff’s] entire file.” (Id.) Plaintiff asserts that these records “were . . . reviewed by Mitchell Dornfeld, psychologist; Jamie Lewis, pain management; and Kevin Cohen, pain management[,]” all of whom were unauthorized to receive the medical records. (Id.) Plaintiff seeks to have his “insurance reinstated [or] . . . to settle [his] claim fully from the day of [insurance] termination to the final year of [] coverage.” (Id.) He also “want[s] Dr. Degregoris to be held accountable for his negligence of [Plaintiff’s] care at the state level for malpractice.” (Id.) Plaintiff seeks $300,000 in damages. (Id.)

DISCUSSION A. Subject Matter Jurisdiction The subject matter jurisdiction of the federal district courts is limited and is set forth in 28 U.S.C. §§ 1331 and 1332. Under these statutes, a federal district court has jurisdiction only when a “federal question” is presented, 28 U.S.C. § 1331, or when plaintiff and defendant are citizens of different states and the amount in controversy exceeds $75,000, 28 U.S.C. § 1332. “[A]ny party or the court sua sponte, at any stage of the proceedings, may raise the question of whether the court has subject matter jurisdiction.” Manway Constr. Co. v. Hous. Auth. Of Hartford, 711 F.2d 501, 503 (2d Cir. 1983) (emphasis added); see Fed. R. Civ. P. 12(h)(3) (“If the court determines at any time that it lacks subject-matter jurisdiction, the court must dismiss the action.”); Ruhrgas AG v. Marathon Oil Co., 526 U.S. 574, 583 (1999) (“[S]ubject-matter delineations must be policed by the courts on their own initiative[.]”). 1. Federal Question To invoke federal question jurisdiction, a plaintiff must assert claims that arise “under the

Constitution, laws, or treaties of the United States.” 28 U.S.C. § 1331. A case arises under federal law if the complaint “establishes either that federal law creates the cause of action or that the plaintiff’s right to relief necessarily depends on resolution of a substantial question of federal law.” Bay Shore Union Free Sch. Dist. v. Kain, 485 F.3d 730, 734-35 (2d Cir. 2007) (quoting Empire Healthchoice Assurance, Inc. v. McVeigh, 547 U.S. 677, 690 (2006)). Mere invocation of federal jurisdiction, without any facts demonstrating a federal law claim, does not create federal subject matter jurisdiction. See Nowak v. Ironworkers Loc. 6 Pension Fund, 81 F.3d 1182, 1189 (2d Cir. 1996).

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

Related

Cite This Page — Counsel Stack

Bluebook (online)
McNeal v. The Hartford Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcneal-v-the-hartford-insurance-company-nysd-2025.