(PS) Stapleton v. United Healthcare Benefits Plan of CA

CourtDistrict Court, E.D. California
DecidedJuly 29, 2025
Docket1:25-cv-00351
StatusUnknown

This text of (PS) Stapleton v. United Healthcare Benefits Plan of CA ((PS) Stapleton v. United Healthcare Benefits Plan of CA) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
(PS) Stapleton v. United Healthcare Benefits Plan of CA, (E.D. Cal. 2025).

Opinion

1 2 3 4

6 UNITED STATES DISTRICT COURT 7 EASTERN DISTRICT OF CALIFORNIA 8 9 JACKIE STAPLETON, Case No. 1:25-cv-00351-SAB 10 Plaintiff, FINDINGS AND RECOMMENDATIONS 11 RECOMMENDING DENYING PLAINTIFF’S v. MOTION TO REMAND AND GRANTING 12 DEFENDANT’S MOTION TO DISMISS UNITED HEALTHCARE BENEFITS PLAN OF CALIFORNIA, 13 ORDER DIRECTING CLERK OF COURT TO Defendant. RANDOMLY ASSIGN A DISTRICT JUDGE 14

15 (ECF Nos. 5, 16)

16 OBJECTIONS DUE WITHIN FOURTEEN DAYS 17

18 Currently before the Court is Plaintiff Jackie Stapleton’s motion to remand this matter to 19 the San Joaquin County Superior Court (ECF No. 16) and Defendant United Healthcare Benefits 20 Plan of California’s motion to dismiss or, in the alternative, motion to strike (ECF No. 5). The 21 Court finds these matters suitable for decision without oral argument. L.R. 230(g). 22 Following amendment of the Local Rules effective March 1, 2022, a certain percentage of 23 civil cases are directly assigned to a Magistrate Judge only, with consent or declination of consent 24 forms due within 90 days from the date of filing of the action. L.R. App. A(m)(1). This action has 25 been directly assigned to a Magistrate Judge only. Not all parties have filed consent or declination 26 of consent forms in this action. Accordingly, pursuant to 28 U.S.C. § 636(b)(1)(B), Local Rule 27 302(c)(7), and Local Rule Appendix A, subsection (m), the Court shall direct the Clerk of the Court 28 to randomly assign a District Judge to this action. 1 Having considered the moving, opposition, and reply papers, the exhibits attached thereto, 2 and the record, the Court recommends, for the following reasons, that Plaintiff’s motion to remand 3 be denied and Defendant’s motion to dismiss be granted with leave to amend. 4 I. 5 BACKGROUND 6 On April 28, 2023, Plaintiff filed a Claim and Order to Go to Small Claims Court 7 (“complaint”) against Defendant in the small claims division of the San Joaquin County Superior 8 Court (“State Court”).1 (See ECF No. 23-1 (“Compl.”) at 2-7.)2 Plaintiff alleges Defendant owes 9 damages for its “refus[al] to pay for a necessary, required, and covered ambulance ride,” which 10 occurred on or around July 1, 2022. (Compl. at 3.) Plaintiff contends the bill amounts to $3,356.34 11 and has accrued interest in the amount of $649.21 (Id.) Plaintiff also requests damages for 12 emotional distress, punitive damages, and costs of hiring a paralegal. (Id.) 13 On November 29, 2023, the State Court conducted a small claims trial in which Defendant 14 failed to appear. (ECF No. 1 at 20.) Judgment was entered against Defendant in the amount of 15 $4,356.34 principal and $75 in costs. (Id. at 20-22.) In or around July 2024, Defendant filed a 16 motion to vacate the judgment due to improper service. (Id. at 23-24.) On August 12, 2024, the 17 State Court granted Defendant’s motion and set aside the judgment. (Id. at 30.) At the same 18 hearing, Defendant waived service at the request of the State Court. (Id.) 19 On October 7, 2024, Plaintiff’s brother-in-law3 emailed Defendant on Plaintiff’s behalf 20 1 Although Defendant attached a file-stamped copy of Plaintiff’s complaint in its December 26, 2024 notice of removal, 21 the copy did not include any completed text fields. (See ECF No. 1 at 8-13.) Defendant filed a notice of errata on January 30, 2025, which purported to attach a correct copy of Plaintiff’s complaint; however, that copy also omits any 22 completed text fields. (ECF No. 8 at 5-10.) On March 28, 2025, Defendant filed a second notice of errata attaching a complete copy of Plaintiff’s complaint. (ECF No. 23-1.) Any reference to Plaintiff’s complaint herein shall be to that 23 filed in Defendant’s second notice of errata, ECF No. 23-1.

24 2 All references to pagination of specific documents pertain to those as indicated on the upper right corners via the CM/ECF electronic court docketing system. 25 3 Despite Plaintiff’s complaint and various emails sent on behalf of Plaintiff claiming significant paralegal costs, Plaintiff explains her brother-in-law, a paralegal, has been assisting her “pro bono” by “typing and filling [sic] things 26 for [Plaintiff]” and “talking to the attorney for [Defendant] as [Plaintiff] get[s] too nervous to speak with her.” (ECF No. 12 at 1.) Should this action proceed beyond these findings and recommendations, Plaintiff is reminded that, when 27 appearing in this Court, “[a]ny individual who is representing himself or herself without an attorney must appear personally or by courtesy appearance by an attorney admitted to the Bar of this Court and may not delegate that duty 28 to any other individual….” L.R. 183(a). 1 offering to settle the action. (ECF No. 16 at 9-10.) Therein, Plaintiff’s brother-in-law stated that 2 “the requirement for transportation within network is only applicable to non-emergency transport 3 (please see: page 5 of UnitedHealthCare Commercial and Individual Exchange, Medical Policy, 4 Non-Emergency Ambulance (Air and Ground, effective 10/1/2023). The ambulance use in question 5 was a clear and unequivocal emergency as defined on page 3, ibid.” Id. (Unedited.) The email also 6 opined that Defendant’s “denial of coverage is outrageous.” Id. 7 On December 4, 2024, Plaintiff’s brother-in-law again emailed Defendant and noted that 8 prior to December 4, 2024, Defendant had forwarded “the Certificate of Coverage.” (ECF No. 1 9 at 47.)4 The email also relayed Plaintiff’s brother-in-law’s understanding that: 10 [A]n insurance company’s “belief that the policy does not provide coverage” is not a basis to refuse a reasonable settlement offer. 11 (Howard v. American National Fire Ins. Co. (2010) 187 Cal.App.4th 498at 525.) Moreover, I believe the California Supreme Court has 12 held an insurance company has a duty “to settle in an appropriate case although the express terms of the policy do not impose such a 13 duty.” (Comunale v. Traders & General Insurance Co. (1958) 50 Cal.2d 645.) It is not reasonable or good faith conduct for an 14 insurance company to refuse to settle based on a “no coverage position.” (Howard, supra, 187 Cal.App.4th at 531.) 15 16 Id. at 48 (unedited). 17 On December 26, 2024, Defendant removed the action to the Sacramento Division on the 18 basis that it was not until the December 4, 2024 email from Plaintiff’s brother-in-law that “it became 19 clear in writing that [the action] is premised on purported obligations of Defendant, the 20 administrator of the operative ERISA-governed plan, to issue benefits notwithstanding coverage 21 and/or the reimbursement methodologies set forth in the plan.” (ECF No. 1 at 4); see 28 U.S.C. § 22 1446(b)(3). Defendant therefore removed the action based on federal question jurisdiction as 23 Plaintiff’s apparent state law claim is completely preempted by Section 502(a) under the Employee 24

25 4 Defendant proffers a redacted version of the December 4, 2024 email in its notice of removal. (See ECF No. 1 at 47- 48.) Plaintiff provides unredacted copies of October 7, 2024 and December 4, 2024 emails between Plaintiff’s brother- in-law and Defendant in support of her unsigned motion to remand. (ECF No. 16 at 7-10.) However, in her unsigned 26 motion to remand, Plaintiff argues the redacted December 4, 2024 email filed by Defendant—the same email she attaches to her own motion—is inadmissible under Rule 408 of the Federal Rules of Evidence. (Id.

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

Related

Metropolitan Life Insurance v. Taylor
481 U.S. 58 (Supreme Court, 1987)
Caterpillar Inc. v. Williams
482 U.S. 386 (Supreme Court, 1987)
Aetna Health Inc. v. Davila
542 U.S. 200 (Supreme Court, 2004)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Matheson v. Progressive Specialty Insurance Company
319 F.3d 1089 (Ninth Circuit, 2003)
Stacie Somers v. Apple, Inc.
729 F.3d 953 (Ninth Circuit, 2013)
Provincial Gov't of Marinduque v. Placer Dome, Inc.
582 F.3d 1083 (Ninth Circuit, 2009)
In Re Nos Communications, Mdl No. 1357
495 F.3d 1052 (Ninth Circuit, 2007)
Leadsinger, Inc. v. BMG Music Publishing
512 F.3d 522 (Ninth Circuit, 2008)
Andrew Smith v. Mylan Inc.
761 F.3d 1042 (Ninth Circuit, 2014)
J. Wilkerson v. B. Wheeler
772 F.3d 834 (Ninth Circuit, 2014)
Connie Dietrich v. the Boeing Company
14 F.4th 1089 (Ninth Circuit, 2021)
Unified Data Services, LLC v. FTC
39 F.4th 1200 (Ninth Circuit, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
(PS) Stapleton v. United Healthcare Benefits Plan of CA, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ps-stapleton-v-united-healthcare-benefits-plan-of-ca-caed-2025.