Methodist Healthcare System of San Antonio, Ltd., L.L.P. v. Blue Shield of California, INC

CourtDistrict Court, W.D. Texas
DecidedMarch 3, 2025
Docket5:23-cv-01414
StatusUnknown

This text of Methodist Healthcare System of San Antonio, Ltd., L.L.P. v. Blue Shield of California, INC (Methodist Healthcare System of San Antonio, Ltd., L.L.P. v. Blue Shield of California, INC) is published on Counsel Stack Legal Research, covering District Court, W.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Methodist Healthcare System of San Antonio, Ltd., L.L.P. v. Blue Shield of California, INC, (W.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

METHODIST HEALTHCARE SYSTEM § OF SAN ANTONIO, LTD., L.L.P., § § SA-23-CV-01414-OLG Plaintiff, § § vs. § § BLUE SHIELD OF CALIFORNIA, INC, § KEENAN AND ASSOCIATES, INC, § § Defendants. §

REPORT AND RECOMMENDATION OF UNITED STATES MAGISTRATE JUDGE

To the Honorable United States District Judge Orlando L. Garcia: This Report and Recommendation concerns Defendant Keenan & Associates, Inc.’s Motion to Dismiss Plaintiff’s First Amended Complaint or Alternatively for a More Definite Statement [#18] and Motion to Dismiss of Defendant Blue Shield of California [#20]. All pretrial matters in this case have been referred to the undersigned for disposition pursuant to Western District of Texas Local Rule CV-72 and Appendix C [#29]. The undersigned therefore has authority to enter this recommendation pursuant to 28 U.S.C. § 636(b)(1)(B). For the reasons set forth below, it is recommended that Defendants’ motions be granted and this case dismissed for lack of subject-matter and personal jurisdiction. I. Background This case arises under the Employee Retirement Income Security Act of 1974 (“ERISA”), 29 U.S.C. §§ 1001, et seq. Plaintiff Methodist Healthcare System of San Antonio, Ltd., L.L.P. (“Methodist”) is a healthcare system located in the Greater San Antonio area of Texas providing medical services to the San Antonio community. (Am. Compl. [#15], at ¶ 8.) Methodist has a Hospital Agreement for PPO/POS Network Participation with Blue Cross Blue Shield of Texas (“BCBSTX”) specifying the terms and conditions of treating patients with any BCBS health plans and the rate of reimbursement for the provision of medically necessary services to those patients. (Id. at ¶ 9.)

This dispute concerns Methodist’s provision of hospital services to two subscribers of health insurance through Defendant Blue Shield of California (“BSCA”), a California-based BCBS health plan Methodist alleges is covered by the Hospital Agreement with BCBSTX. (Id. at ¶ 12.) The Amended Complaint refers to the subscribers/patients at issue as B.R. and A.M.A. (Id. at ¶¶ 13, 23.) Methodist claims BSCA and its plan administrator, Keenan and Associates, Inc. (“Keenan”), wrongfully refused to pay Methodist for the patients’ treatment on the basis that the treatment was not medically necessary. (Id.) Methodist asserts that Defendants’ conduct violates ERISA. (Id. at ¶¶ 37–45.) Methodist alternatively pleads breach of contract to the extent that the health plans at issue are not subject to ERISA. (Id. at ¶ 47.)

Defendants each filed a motion to dismiss Methodist’s Amended Complaint. Methodist filed responses to the motions [#21, #23], to which Defendants filed their replies [#25, #27]. Plaintiff also filed a sur-reply [#28] regarding Keenan’s motion. In its motion, Kennan argues the Court should dismiss the Amended Complaint pursuant to Rule 12(b)(1) for lack of subject matter jurisdiction, Rule 12(b)(2) for lack of personal jurisdiction, Rule 12(b)(3) for improper venue, Rule 12(b)(6) for failure to sufficiently plead the ERISA and breach-of-contract claims, and Rule 12(b)(7) for failure to join a necessary and indispensable party. BSCA adopts all of Keenan’s arguments for dismissal in its separate motion to dismiss and advances additional Rule 12(b)(1) arguments regarding subject-matter jurisdiction. Both Defendants alternatively move for a more definite statement pursuant to Rule 12(e). Methodist requests leave to amend its pleadings if the Court finds any of Defendants’ arguments to have merit. Because Defendants challenge the Court’s subject matter jurisdiction, the undersigned is required to first evaluate Defendants’ Rule 12(b)(1) arguments. McLin v. Twenty-First Jud. Dist., 79 F.4th 411, 415 (5th Cir. 2023).

II. Subject-Matter Jurisdiction Over ERISA Claim Defendants seek dismissal of Methodist’s ERISA claim for lack of standing pursuant to Rule 12(b)(1) of the Federal Rules of Civil Procedure. The District Court should find that the jurisdictional record establishes that A.M.A.’s plan is not an ERISA plan and that Methodist has failed to satisfy its burden to demonstrate derivative standing to bring an ERISA claim on behalf of B.R. A. Legal Standard “The standing doctrine defines and limits the role of the judiciary and is a threshold inquiry to adjudication.” McClure v. Ashcroft, 335 F.3d 404, 408 (5th Cir. 2003). “In essence

the question of standing is whether the litigant is entitled to have the court decide the merits of the dispute or of particular issues.” Warth v. Seldin, 422 U.S. 490, 498 (1975). The concept of standing encompasses both constitutional and other concerns, such as prudential and contractual standing. Id. A plaintiff must have constitutional standing as required by Article III of the Constitution. St. Paul Fire & Marine Ins. Co. v. Labuzan, 579 F.3d 533, 539 (5th Cir. 2009). Prudential standing relates to whether a grievance falls within the zone of interests protected by the statute invoked and evaluates whether a plaintiff is asserting his or her own legal rights rather than the interests of third parties. Id. Contractual standing concerns whether a party has a right to enforce a contract and can be referred to as derivative or third-party standing. See Maxim Crane Works, L.P. v. Zurich Am. Ins. Co., 11 F.4th 345, 350 (5th Cir. 2021) (per curiam). Whether Methodist has derivative standing is not a question of constitutional standing but rather implicates contractual concerns. Mem’l Hermann Health Sys. v. Pennwell Corp. Med. & Vision Plan, No. CV H-17-2364, 2017 WL 6561165, at *5 (S.D. Tex. Dec. 22, 2017). Methodist brings its ERISA claim pursuant to Section 502(a)(1)(B) of ERISA, which

authorizes a suit by a plan participant or beneficiary “to recover benefits due to him under the terms of his plan, to enforce his rights under the terms of the plan, or to clarify his rights to future benefits under the terms of the plan.” 29 U.S.C. § 1132(a)(1)(B). Healthcare providers do not have standing to sue to collect benefits under an ERISA plan, but they may obtain assignments from their patients and thereby have derivative standing to bring ERISA actions to recover benefits. Mem’l Hermann Health Sys., 2017 WL 6561165, at *5 (citing N. Cypress Med. Ctr. Operating Co., Ltd. v. Cigna Healthcare, 781 F.3d 182, 191 & n.31 (5th Cir. 2015)); see also Harris Methodist Fort Worth v. Sales Support Servs., Inc. Emp. Health Care Plan, 426 F.3d 333–34 (5th Cir. 2005) (“It is well established that a healthcare provider, though not a statutorily

designated ERISA beneficiary, may obtain standing to sue derivatively to enforce an ERISA plan beneficiary’s claim.”)). Although Methodist is not a plan participant or beneficiary of an ERISA plan, it alleges it has derivative standing to enforce the terms of the plans based on B.R.’s and A.M.A.’s assignment of benefits and rights to Methodist upon admission for treatment to the hospital. (Am. Compl. [#15], at ¶¶ 41, 43, 48, 95.) Initially, Defendants made two arguments regarding Methodist’s assertion of derivative standing.

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Methodist Healthcare System of San Antonio, Ltd., L.L.P. v. Blue Shield of California, INC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/methodist-healthcare-system-of-san-antonio-ltd-llp-v-blue-shield-of-txwd-2025.