Patterson v. UnitedHealthcare Insurance Company

CourtDistrict Court, N.D. Ohio
DecidedJanuary 9, 2025
Docket1:21-cv-00470
StatusUnknown

This text of Patterson v. UnitedHealthcare Insurance Company (Patterson v. UnitedHealthcare Insurance Company) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Patterson v. UnitedHealthcare Insurance Company, (N.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

ERIC L. PATTERSON, ) Case No. 1:21-cv-470 ) Case No. 1:23-cv-378 Plaintiff, ) ) Judge J. Philip Calabrese v. ) ) Magistrate Judge UNITEDHEALTHCARE ) Jonathan D. Greenberg INSURANCE COMPANY, et al., ) ) Defendants. ) )

OPINION AND ORDER Plaintiff Eric Patterson and his wife were involved in separate car accidents a few months apart. He sued the driver of the other car involved in the accident and obtained a settlement. Mr. Patterson’s health insurance provider pursued reimbursement of the costs it paid as a result of the accident. It did so pursuant to a provision in a summary plan description of the policy terms, while maintaining in litigation that no plan document existed. Eventually, Mr. Patterson and his insurer settled for $25,000. When Mr. Patterson’s wife found herself in the same situation, the same insurer provided a plan document in discovery in her case in State court, resulting in several lawsuits among the parties. This federal lawsuit brought claims under the Employee Retirement Income Security Act of 1974 and State law. The court dismissed the federal claims and declined to exercise jurisdiction over the State- law claims, which Plaintiff later refiled in State court. On appeal, the Sixth Circuit held that ERISA authorized Mr. Patterson to sue for breach of fiduciary duty and prohibited transactions to seek equitable relief resulting in the return of the $25,000 he paid in State court to resolve litigation over

his insurer’s subrogation and reimbursement rights. Otherwise, the appellate court affirmed and held that Mr. Patterson had standing only to pursue his own claims, not claims on behalf of others through a class action. It left several other pleading-stage inquiries for the Court to resolve in the first instance. When the case returned on remand from the Sixth Circuit, the parties undertook efforts at mediation, which did not ultimately result in a resolution. In

the meantime, Plaintiff refiled his State-law claims in State court on behalf of a class, and Defendants removed that action on the basis of federal preemption. Also, Defendants moved to dismiss that lawsuit or, in the alternative, to strike the class allegations. For his part, Plaintiff moved to remand the case to State court. In this ruling, the Court attempts to cut through this procedural tangle in these two lawsuits, which began as one. First, the Court addresses the tasks the Sixth Circuit left at the pleading stage regarding the ERISA claims Plaintiff asserts.

Second, the Court turns to Plaintiff’s second lawsuit, initially filed in State court, and the parties’ competing motions directed at it. STATEMENT OF THE FACTS On Defendants’ motion to dismiss, the Court takes the facts alleged in the complaint as true and takes judicial notice of State-court opinions and proceedings mentioned in the complaint, without converting this motion into one for summary judgment. See Wyser-Pratte Mgmt. Co. v. Telxon Corp., 413 F.3d 553, 560 (6th Cir. 2005). A. Eric Patterson’s Case in State Court

In November 2014, Mr. Patterson was injured in a motor vehicle accident. (ECF No. 1, ¶ 30, PageID #16.) He had health insurance through his employer, Swagelok Company. (Id., ¶ 11, PageID #9.) United Healthcare, an umbrella term for a group of affiliated companies, administered the plan. (Id., ¶ 12, PageID #10.) After the accident, United Healthcare paid for Mr. Patterson’s medical treatment. (Id., ¶ 31, PageID #16.) Mr. Patterson also submitted a claim for compensation to the insurer of the other vehicle. (Id., ¶ 30, PageID #16.)

United Healthcare’s agent and subsidiary, Optum, notified Mr. Patterson that it would invoke the plan’s rights to subrogation and reimbursement should he recover from the insurer of the other driver. (Id., ¶ 31, PageID #16.) A summary plan description that United Healthcare provided to Mr. Patterson noted these subrogation and reimbursement rights. (Id., ¶¶ 27–28, PageID #14–15.) By its terms, the summary plan description serves only as a summary, and any inconsistent

language in the plan document supersedes it. (Id., ¶ 27, PageID #14.) United Healthcare did not provide Mr. Patterson with any plan documents—only the summary plan description. In November 2016, Mr. Patterson and his wife, Laura Patterson, sued the other insurer for compensatory damages in State court. (Id., ¶ 32, PageID #16; Patterson v. Nationwide Truck Brokers, Inc., No. CV-2016-11-4906 (Summit Cnty. C.P. filed Nov. 18, 2016).) In the same suit, Mr. Patterson joined a claim against his insurance plan and United Healthcare seeking a declaratory judgment regarding the subrogation and reimbursement rights in his contract. (ECF No. 1, ¶ 32, PageID #16.) Throughout the proceedings in State court, United Healthcare’s attorneys

maintained that no plan document existed, just the summary plan description. (Id., ¶ 34, PageID #17–21.) In June 2017, Mr. Patterson settled with the plan, agreeing to pay Optum $25,000 in satisfaction of the plan’s subrogation and reimbursement rights. (Id., ¶ 35, PageID #21.) B. Laura Patterson’s Case in State Court In July 2015, months after Eric Patterson’s accident, Laura Patterson suffered

injuries in a motor vehicle accident. (Id., ¶ 36, PageID #22.) Ms. Patterson was covered under the same health insurance plan, was also contacted by Optum regarding its subrogation and reimbursement rights, and in June 2017 also sued in State court for a declaratory judgment against the plan to determine its subrogation and reimbursement rights. (Id., ¶¶ 36–38, PageID #21–22.) Initially, the defendants relied on the same summary plan description and again claimed that no other plan

document existed. (Id., ¶ 39, PageID #22.) In February 2018, however, the defendants produced a plan document “for the first time.” (Id., ¶ 49, PageID #28.) Like the summary plan description, the plan document stated that, in the event of a discrepancy, the plan document—and not the summary plan description—controls. (ECF No. 1-1, PageID #99.) Unlike the summary plan description, the plan document did not contain a subrogation or reimbursement provision. (ECF No. 1-1; ECF No. 1, ¶ 49, PageID #28.) After production of the plan document, the State court entered summary judgment in favor of Ms. Patterson against the plan, holding that she was not contractually obligated to reimburse the plan for any medical benefits it paid on her

behalf. (ECF No. 1, ¶ 52, PageID #29.) STATEMENT OF THE CASE In March 2020, Ms. Patterson sued United Healthcare, Optum, Swagelok, and their lawyers in federal court, bringing claims under the Employee Retirement Income Security Act of 1974, the Fair Debt Collection Practices Act, and State law. (Patterson v. Swagelok Co., No. 1:20-cv-566, ECF No. 1 (N.D. Ohio Mar. 17, 2020).) A

year later, Mr. Patterson sued the same defendants (including an additional Optum entity and naming individual lawyers as defendants), bringing claims under ERISA and State law. (ECF No. 1.) Although these separate lawsuits involved the same plan, the same claims and issues, and the same counsel, no party in either lawsuit notified the Court of the other case’s existence or identified it as a related case. In this ruling, the Court addresses this second lawsuit, which now has two parts.

A. Dismissal and Re-Filing of the State-Law Claims In March 2021, Defendants moved to dismiss the complaint for failure to state a claim and for lack of subject-matter jurisdiction. (ECF No. 11.) While the motion to dismiss was pending, Plaintiff moved for leave to amend his complaint to add class allegations, narrow the factual allegations, and drop certain Defendants and claims. (ECF No.

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Patterson v. UnitedHealthcare Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/patterson-v-unitedhealthcare-insurance-company-ohnd-2025.