Series 15-09-321 v. State Farm mutual Automobile Insurance Company

CourtDistrict Court, S.D. Florida
DecidedJanuary 8, 2025
Docket1:23-cv-22982
StatusUnknown

This text of Series 15-09-321 v. State Farm mutual Automobile Insurance Company (Series 15-09-321 v. State Farm mutual Automobile Insurance Company) is published on Counsel Stack Legal Research, covering District Court, S.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Series 15-09-321 v. State Farm mutual Automobile Insurance Company, (S.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 1:23-CV-22982-WILLIAMS/REID

SERIES 15-09-321, a Delaware entity,

Plaintiff,

vs.

STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY,

Defendant. ________________________

REPORT AND RECOMMENDATION ON MOTION TO DISMISS THE SECOND AMENDED COMPLAINT

This matter is before the Court upon Defendant State Farm Mutual Automobile Insurance Company’s (“Defendant” or “State Farm”) Motion to Dismiss the Second Amended Complaint (“SAC”) at ECF No. 127 (the “Motion”) [ECF No. 130] The Honorable Kathleen M. Williams referred this matter to the undersigned. [ECF Nos. 132]. After hearing argument at the December 17, 2024 sealed hearing on the Motion and having carefully considered the Motion to Dismiss, Plaintiff’s Opposition [ECF No. 135], Defendant’s Reply [ECF No. 136], and the relevant legal authorities, the undersigned RECOMMENDS that Defendant’s Motion to Dismiss [ECF No. 130] be GRANTED in part and DENIED in part.1 BACKGROUND “Once you cut through the acrimonious history between the parties, and the intricate regulatory backdrop, this case boils down to one insurer’s alleged failure to reimburse another.” MSP Recovery Claims, Series 44, LLC v. Zurich Am. Ins. Co., No. 22-CV-5054, 2023 WL

1 This is Defendant’s third Motion to Dismiss. [See ECF Nos. 29, 61, 130]. 5227396, at *1 (N.D. Ill. Aug. 15, 2023). This lawsuit is one of dozens filed in courts across the country arising from the Medicare Secondary Payer Act (the “MSP Act”). 42 U.S.C. § 1395y(b)(1). Through the MSP Act, Congress mandated that insurers, such as Defendant State Farm, would become primary payers and Medicare would provide a safety net for its beneficiaries.

[ECF No. 127 ¶ 3]. Congress later enacted Medicare Part C, which ensures Medicare Advantage Organizations (“MAOs”), like Medicare, “would be deemed the secondary payer when the Medicare beneficiaries’ medical expenses are covered concurrently by other insurance policies.” [Id. ¶ 4 (citing 42 U.S.C. § 1395w-22(a)(4))]. Thus, when Medicare or an MAO make a payment that a primary payer was responsible for, the payment is made conditional. [Id. ¶ 5 (citing 42 C.F.R. § 411.21)]. The MSP Act provides a private cause of action for private entities to recover these conditional payments when insurers fail to reimburse Medicare and MAOs. [Id. ¶ 6; See 42 U.S.C. § 1395y(b)(2)(b)(iii)) and (b)(3)(A)]. The statute allows secondary payers to collect double damages. [42 U.S.C. § (b)(3)(A)]. Plaintiff Series 15-09-321 is a Delaware LLC and assignee of the MAO Assignor’s rights

to recovery, pursuant to a December 23, 2021, Assignment Agreement. [Id. ¶¶ 12, 73, 78]. Defendant State Farm is an insurer that provides liability and no-fault policies. [Id. ¶ 14]. Plaintiff alleges that Defendant has (1) done little to coordinate with—or reimburse—MAOs who have made conditional payments, and (2) failed to report to Medicare its status as a primary payer and other information pursuant to Section 111 of the Medicare Act, Medicaid, and SCHIP Extension Act of 2007, PL 110-173. [Id. ¶¶ 9–10]. These actions formed the basis for the instant lawsuit. Counts I and II of the SAC allege a private cause of action under 42 U.S.C. § 1395y(b)(3)(A) for settlement claims and for first-party claims, respectively. [ECF No. 127 ¶¶ 123–146]. Count III alleges breach of contract for failure to pay benefits for the contractual claims. [Id. at ¶¶ 147–155]. Count IV alleged fraudulent concealment. [Id. ¶¶ 156–166]. Count V request declaratory relief (pursuant to 28 U.S.C. § 2201) that (1) State Farm must determine whether its insureds are covered by the MAO Assignor and must coordinate benefits with the MAO; (2) State Farm must alert the MAO Assignor of its primary payer obligations; (3) the MAO Assignor is not

obligated to submit a demand for reimbursement on a properly completed 1500 Claim Form, UB 92 Form, or any other standard form under any relevant no-fault statute; and (4) Secondary Payers are not obligated to comply with the strict requirements of any applicable no-fault statute. [Id. ¶¶ 167–176]. This action has been pending since August 8, 2023. [ECF No. 1]. Pursuant to the agreement between Plaintiff and Assignor, Plaintiff contends it was assigned 297 cases. [ECF No. 127 ¶ 58; ECF No. 127-1]. Eight are described in the body of the SAC. [ECF No. 127 ¶¶ 90–8]. The remaining 289 are described in Exhibit A. [ECF No. 127-1]. The undersigned previously recommended that the district judge grant the Motion to Dismiss for lack of standing. [ECF No. 115]. Plaintiff has since amended its complaint and filed

its Assignment Agreement under seal. LEGAL STANDARD I. Standing A challenge to a plaintiff’s standing to bring a lawsuit is analyzed under Federal Rule 12(b)(1). MSP Recovery Claims, Series LLC v. Amerisure Ins. Co., No. 20-24077-Civ, 2021 WL 358670, at *1 (S.D. Fla. Feb. 1, 2021). As standing is jurisdictional, it has the same effect as a dismissal for lack of subject matter jurisdiction pursuant to Federal Rule 12(b)(1). Id. (discussing Stalley ex rel. United States v. Orlando Reg’l Healthcare Sys., Inc., 524 F.3d 1244, 1251 (11th Cir. 2008)). A motion to dismiss pursuant to Rule 12(b)(1) may be based on either a facial or factual attack to the complaint. Id. A facial attack asks whether the plaintiff has alleged a sufficient basis for subject matter jurisdiction whereas a factual attack requires the Court to consider matters outside the pleadings such as testimony and affidavits. Id. In order to prove standing, a plaintiff must allege he has suffered (1) an injury in fact, (2)

that is fairly traceable to the challenged conduct of the defendant, and (3) that is likely to be redressed by a favorable judicial decision. Spokeo, Inc. v. Robins, 136 S. Ct. 1540, 1547 (2016). To establish an injury in fact, a plaintiff must show that he suffered an invasion of a legally protected interest that is concrete and particularized and actual and imminent, not conjectural or hypothetical. Id. at 1548. For the injury to be concrete, it must be real and not abstract. Id. at 1548– 49. For an injury to be particularized, it must impact the plaintiff in a personal and individual way. Id. at 1548. “[T]he assignee of a claim has standing to assert [an] injury in fact suffered by the assignor.” MSPA Claims 1, LLC v. Tenet Florida, Inc., 918 F.3d 1312, 1317 (11th Cir. 2019) (quoting Sprint Commc’ns Co. v. APCC Servs., Inc., 554 U.S. 269, 286 (2008)). Under the MSP

Act, an assignee has standing to sue if “(1) it’s ultimate assignor suffered an injury-in-fact, and (2) the assignor’s claim arising from that injury was validly assigned.” MSP Recovery Claims, Series LLC v. QBE Holdings, Inc., 965 F.3d 1210, 1217 (11th Cir. 2020). II. Failure to State a Claim A pleading need only contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). “[T]he pleading standard Rule 8 . . .

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