Peters v. Medical Mutual of Ohio

CourtDistrict Court, N.D. Illinois
DecidedSeptember 29, 2025
Docket1:24-cv-06949
StatusUnknown

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

Bluebook
Peters v. Medical Mutual of Ohio, (N.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

BEVERLY PETERS and TIM PETERS, ) individually and on behalf of all others ) similarly situated, ) No. 24 CV 6949 ) Plaintiffs, ) Judge Jeffrey I. Cummings ) v. ) ) MEDICAL MUTUAL OF OHIO, ) RESERVE NATIONAL INSURANCE ) COMPANY, KEMPER ) CORPORATION, and UNITED ) INSURANCE COMPANY OF ) AMERICA, ) ) Defendants. )

MEMORANDUM OPINION AND ORDER

Plaintiffs Beverly Peters and Tim Peters, (“plaintiffs”) were enrolled in an insurance plan and elected supplemental coverage for cancer treatment. While Mr. Peters was undergoing covered treatment for his cancer diagnosis, plaintiffs’ insurance was cancelled. Plaintiffs subsequently initiated this lawsuit against the insurance companies involved in the administration of their plan: namely, Medical Mutual of Ohio (“Medical Mutual”), Reserve National Insurance Company (“Reserve National”), Kemper Corporation (“Kemper”), and United Insurance Company of America (“United Insurance”). Plaintiffs bring this case pursuant to 28 U.S.C. §1332(d) and allege the four following causes of action: breach of contract and breach of the duty of good faith and fair dealing; fraud; vexatious and unreasonable denial of claims; and civil conspiracy. Defendants have filed two separate motions, (Dckt. ##32, 29), seeking to dismiss each claim, except for plaintiffs’ breach of contract claim, pursuant to Federal Rule 12(b)(6). For the reasons set forth below, Kemper and United Insurance’s motion to dismiss, (Dckt. #39), is granted in part and denied in part, and Medical Mutual and Reserve National’s motion to dismiss, (Dckt. #32), is granted in part and denied in part. I. LEGAL STANDARD UNDER RULE 12(b)(6)

To survive a Rule 12(b)(6) motion to dismiss, a complaint must “state a claim to relief that is plausible on its face.” Bell. Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim is plausible when the plaintiff “pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). When considering a motion to dismiss under Rule 12(b)(6), the Court construes “the complaint in the light most favorable to the [non-moving party] accepting as true all well-pleaded facts and drawing reasonable inferences in [the non-moving party’s] favor.” Yeftich v. Navistar, Inc., 722 F.3d 911, 915 (7th Cir. 2013). When resolving a motion under Rule 12(b)(6), “in addition to the allegations set forth in the complaint itself,” the Court may consider, “documents that are attached to the complaint,

documents that are central to the complaint and are referred to in it, and information that is properly subject to judicial notice.” Williamson v. Curran, 714 F.3d 432, 436 (7th Cir. 2013). Indeed, it is “well-settled in this circuit that documents attached to a motion to dismiss are considered part of the pleadings if they are referred to in the plaintiff’s complaint and are central to [its] claim.” Mueller v. Apple Leisure Corp., 880 F.3d 890, 895 (7th Cir. 2018) (cleaned up); Kuebler v. Vectren Corp., 13 F.4th 631, 636 (7th Cir. 2021) (same, citing cases). II. FACTUAL BACKGROUND ALLEGED IN THE COMPLAINT The Court draws the facts set forth below from: (1) the facts pleaded in the amended complaint (the “Complaint”), (Dckt. #27); and (2) the documents attached to the Complaint as exhibits, including the Certificate of Insurance for a Group Cancer and Specified Disease Insurance Policy (the “Certificate”) and the December 19, 2022 insurance coverage termination letter (“Coverage Termination Letter”). A. Plaintiffs’ Insurance Policies and Subsequent Termination of those Policies. Plaintiffs owned a Certificate issued by defendant Reserve National, which at the time of

issuance was a subsidiary of defendant United Insurance, which in turn was a subsidiary of defendant Kemper. (Dckt. #27 ¶13). Although the Certificate was issued by Reserve National, several of the benefit checks that plaintiffs received bore Kemper’s logo. (Id. ¶9). The underlying group policy was issued to the Lawrence County School System, where Mrs. Peters was a schoolteacher. (Id. ¶14). Reserve National received a request from the Lawrence County School System for termination of the group policy with an effective termination date of August 31, 2022. (Id. ¶25). Relevant here, the Certificate allowed insureds, like plaintiffs, to port their coverage under certain circumstances so that they could continue receiving the benefits of coverage despite

termination of the underlying policy. (Id. ¶29). Plaintiffs secured continuing coverage through the portability provision of the Certificate and were receiving benefits for cancer treatment when, on December 19, 2022, they were notified that their “[c]ancer coverage ha[d] terminated effective 2.28.2023.” (Id. ¶¶30, 35; Dckt. #27-2). The Coverage Termination Letter was sent on Kemper Health letterhead and directed plaintiffs to contact the Kemper Service Center by phone or email with any questions. (Dckt. #27-2). Plaintiffs continued to submit charges, and Kemper continued to pay their claims, through the end of February 2023. (Dckt. #27 ¶39). After February 2023, Kemper refused to pay for additional claims, and after May 2023, the denials came from Medical Mutual. (Id.). The reasons provided for the denials were that the claims were “not covered by plan” (identified as service code “888”), “not covered per plan guidelines” (identified as reason code “PG”), and that there was “no coverage for date of service” (identified as reason code “26”). (Id. ¶72). B. Medical Mutual Acquires Reserve National. Days before the Coverage Termination Letter was sent, Medical Mutual acquired Reserve

National from Kemper. (Id. ¶37). Plaintiffs allege that as part of the acquisition, Kemper, United Insurance, and Medical Mutual collectively executed a plan to terminate substantially all of the ported group supplemental coverage that Reserve National had on its books, which had the effect of “closing a book of business that was providing accident and health coverage to over 30,000 insureds.” (Id. ¶38). According to plaintiffs, defendants terminated their coverage to “substantially reduc[e] the liabilities acquired by Medical Mutual,” (id. ¶4), “to make the sale [of Reserve National] more attractive,” (id. ¶69). C. The Present Lawsuit. Plaintiffs bring the following claims: breach of contract and breach of fiduciary duty

against Reserve National (Count I); fraud against Reserve National and its former parent companies Kemper and United Insurance (Count II); violations of Section 155 of the Illinois Insurance Code (“Section 155”) against all defendants (Count III); and civil conspiracy against all defendants (Count IV). Defendants have moved to dismiss the claims against them except for the breach of contract claim. The Court addresses the parties’ arguments in turn below. III. ANALYSIS A. Plaintiffs Have Sufficiently Alleged Actions by Kemper and United Insurance Such That They Should Not Be Dismissed as Defendants at this Stage.

Kemper and United Insurance move to dismiss the claims against them on grounds that: (1) they are separate entities from Reserve National; (2) as parent corporations, they generally are “not liable for the actions of a subsidiary;” and (3) they cannot be liable for any actions alleged in the Complaint because the complained-of policy termination took place after United Insurance sold Reserve National to Medical Mutual on December 1, 2022.

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Peters v. Medical Mutual of Ohio, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peters-v-medical-mutual-of-ohio-ilnd-2025.