Prime Healthcare Centinela v. United Healthcare Ins. Co. CA2/5

CourtCalifornia Court of Appeal
DecidedOctober 20, 2025
DocketB334746
StatusUnpublished

This text of Prime Healthcare Centinela v. United Healthcare Ins. Co. CA2/5 (Prime Healthcare Centinela v. United Healthcare Ins. Co. CA2/5) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Prime Healthcare Centinela v. United Healthcare Ins. Co. CA2/5, (Cal. Ct. App. 2025).

Opinion

Filed 10/20/25 Prime Healthcare Centinela v. United Healthcare Ins. Co. CA2/5 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION FIVE

PRIME HEALTHCARE B334746 CENTINELA, LLC et al., (Los Angeles County Plaintiffs and Appellants, Super. Ct. No. 22STCV08452) v.

UNITED HEALTHCARE INSURANCE COMPANY,

Defendant and Respondent.

APPEAL from an order of the Superior Court of Los Angeles County, Lawrence P. Riff, Judge. Affirmed.

Buchalter, Damaris L. Medina, Devan J. McCarty, Robert M. Dato, Efrat M. Cogan and Karen N. George for Plaintiffs and Appellants. Crowell & Moring, Nathaniel J. Wood, Marlee J. Godinho Santos; Gibson, Dunn & Crutcher, Kahn A. Scolnick, Matt A. Getz, and Allison R. Kawachi for Defendant and Respondent.

****** Hospitals that “operate[] an emergency department” open “to the public” are obligated—under federal and state law—to provide emergency services to anyone who is “in danger of loss of life, or serious injury or illness.” (Health & Saf. Code, § 1317, subd. (a); 42 U.S.C. § 1395dd(b).) The portion of the Health and Safety Code enacted as the Knox-Keene Health Care Service Plan Act of 1975 (Health & Saf. Code, § 1340 et seq.) (the Knox-Keene Act) explicitly imposes a duty upon “health care service plan[s],” which are regulated by the Department of Managed Health Care (DMHC), to directly “reimburse” hospitals who are outside of the plans’ contracted network for their provision of such services at their “reasonable and customary value.” (Id., § 1371.4, subd. (b); Cal. Code Regs., tit. 28, § 1300.71, subd. (a)(3); Bell v. Blue Cross of California (2005) 131 Cal.App.4th 211, 215-216 (Bell).) Does a similar duty to directly reimburse out-of-network hospitals for the reasonable and customary value of any emergency services they provide exist for health insurance companies regulated by the Department of Insurance? We hold that it does not: The Insurance Code does not explicitly impose such a duty and the canons of statutory construction counsel against inferring such a duty from other provisions of the Insurance Code or their legislative history, by analogy to the Knox-Keene Act, or from the common law. Because the question whether insurance companies should have a duty to directly reimburse for such

2 services is one of public policy, it is a question for the Legislature and not this court. We must accordingly affirm the trial court’s judgment dismissing the claims of several hospitals against an insurance company premised upon the existence of that duty. FACTS AND PROCEDURAL BACKGROUND I. Facts Prime Healthcare (Prime) operates hospitals throughout Southern California, including in Chino Valley, Huntington Beach, Sherman Oaks, and Anaheim (collectively, the hospitals); each has an emergency department.1 Since January 1, 2020, these hospitals have provided emergency services to patients who have health insurance with United Healthcare Insurance Company, Inc. (United) or who are members of the UHC of California, Inc. health insurance service plan (UHC), even though the hospitals are not part of United or UHC’s network of providers. United and UHC have “ma[de] payments” to Prime “on a large number of claims,” but in what Prime views as “inadequate amounts.” II. Procedural Background A. Complaint On March 9, 2022, Prime sued United and UHC for (1) quantum meruit, (2) open book account, and (3) violation of California’s Unfair Competition Law (Bus. & Prof. Code, § 17200

1 The corporate names of the five hospitals are (1) Prime Healthcare Centinela, LLC, dba Centinela Hospital Medical Center; (2) Veritas Health Services, Inc., dba Chino Valley Medical Center; (3) Prime Healthcare Huntington Beach, LLC, dba Huntington Beach Hospital; (4) Prime Healthcare Services – Sherman Oaks, LLC, dba Sherman Oaks Hospital; and (5) Prime Healthcare Anaheim, LLC, dba West Anaheim Medical Center.

3 et seq.) (UCL).2 All of these claims are premised on United’s and UHC’s alleged failure to “pay the reasonable value of emergency medical services provided” by the hospitals. (Italics added.) B. United’s demurrer United—but not UHC—demurred, arguing that it owed no duty to directly reimburse Prime the reasonable value of the emergency services its hospitals provided.3 After fulsome briefing and two hearings, the trial court issued a 13-page order sustaining the demurrer without leave to amend. The court reasoned that the Insurance Code that regulates health insurance companies like United does not explicitly obligate insurers to directly reimburse the out-of-network providers of emergency services, and the court refused to infer such an obligation from the Insurance Code’s obligation that insurers “cover emergency services” in their policies because “an insurer’s statutory duty to provide insurance coverage to insureds does not necessarily imply a duty to reimburse providers the reasonable and customary value of the providers’ services.” (Italics in original.) The court also rejected Prime’s proffered analogy to the Knox-Keene Act because the Insurance Code “lacks the express statutory duty to reimburse” providers that exists in the Knox- Keene Act. (Italics omitted.) Because no statute mandated direct

2 Although Prime also asserted a separate claim for “services rendered,” that claim is substantively duplicative of its equitable claim for quantum meruit. (See Port Medical Wellness, Inc. v. Connecticut General Life Ins. Co. (2018) 24 Cal.App.5th 153, 180.) We accordingly do not separately discuss it.

3 United also argued that the claims were barred by the doctrine of collateral estoppel, but the trial court rejected that argument and the parties do not renew it on appeal.

4 reimbursement at a reasonable rate, the fundamental premise of all of Prime’s claims was absent and necessitated dismissal.4 C. Appeal Following entry of an order dismissing United from the action, Prime filed this timely appeal. DISCUSSION All of Prime’s claims against United have the same underlying premise—namely, that United has a duty to directly reimburse Prime for the “customary and reasonable” value of the emergency services that Prime’s hospitals provided to United’s insureds.5 In reviewing the trial court’s order dismissing these claims on demurrer, “‘we accept the truth of material facts properly pleaded in the operative complaint, but not contentions, deductions, or conclusions of fact or law.’” (Capito v. San Jose Healthcare System, LP (2024) 17 Cal.5th 273, 280; Ranger v.

4 In addition to finding that this overarching premise of Prime’s complaint failed, the trial court also explained why each of Prime’s claims failed as to certain required elements. Because our holding does not depend on the specific elements of each of Prime’s claims, we need not discuss this further rationale by the trial court.

5 Although Prime’s UCL claim was phrased in terms of United’s conduct being “unfair” as well as “unlawful,” and although those two prongs can be distinct (Cel-Tech Communications, Inc. v. Los Angeles Cellular Telephone Co. (1999) 20 Cal.4th 163, 180), Prime did not treat them as distinct in its complaint, alleging that United’s conduct was unfair because “it prevents the laws relating to services for emergency services and payment from protecting emergency providers and patients, as intended,” which is alleged to have the effect of discouraging higher payments to those providers.

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Prime Healthcare Centinela v. United Healthcare Ins. Co. CA2/5, Counsel Stack Legal Research, https://law.counselstack.com/opinion/prime-healthcare-centinela-v-united-healthcare-ins-co-ca25-calctapp-2025.