UnitedHealthcare of Mississippi, Inc. v. Amerigroup Mississippi, Inc., Magnolia Health Plan, Inc., Molina Healthcare of Mississippi, Inc., Mississippi True d/b/a Truecare and Mississippi Division of Medicaid

CourtMississippi Supreme Court
DecidedJune 20, 2024
Docket2022-SA-01216-SCT
StatusPublished

This text of UnitedHealthcare of Mississippi, Inc. v. Amerigroup Mississippi, Inc., Magnolia Health Plan, Inc., Molina Healthcare of Mississippi, Inc., Mississippi True d/b/a Truecare and Mississippi Division of Medicaid (UnitedHealthcare of Mississippi, Inc. v. Amerigroup Mississippi, Inc., Magnolia Health Plan, Inc., Molina Healthcare of Mississippi, Inc., Mississippi True d/b/a Truecare and Mississippi Division of Medicaid) is published on Counsel Stack Legal Research, covering Mississippi Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
UnitedHealthcare of Mississippi, Inc. v. Amerigroup Mississippi, Inc., Magnolia Health Plan, Inc., Molina Healthcare of Mississippi, Inc., Mississippi True d/b/a Truecare and Mississippi Division of Medicaid, (Mich. 2024).

Opinion

IN THE SUPREME COURT OF MISSISSIPPI

NO. 2022-SA-01216-SCT

UNITEDHEALTHCARE OF MISSISSIPPI, INC.

v.

AMERIGROUP MISSISSIPPI, INC., MAGNOLIA HEALTH PLAN, INC., MOLINA HEALTHCARE OF MISSISSIPPI, INC., MISSISSIPPI TRUE D/B/A TRUECARE AND MISSISSIPPI DIVISION OF MEDICAID

DATE OF JUDGMENT: 11/15/2022 TRIAL JUDGE: HON. TIFFANY PIAZZA GROVE TRIAL COURT ATTORNEYS: SAMMY LEE BROWN, JR. BRIAN PARKER BERRY HUGH RUSTON COMLEY GLEN AUSTIN STEWART KATIE CAMILLE BERRY GEORGE H. RITTER JOHN P. SNEED MARY MARGARET GAY COURT FROM WHICH APPEALED: HINDS COUNTY CHANCERY COURT ATTORNEYS FOR APPELLANT: MARY MARGARET GAY KERI SULLIVAN HENLEY ERIC J. WEISENBURGER ALEX P. HONTOS ATTORNEYS FOR APPELLEES: GEORGE H. RITTER DONNA BROWN JACOBS TIMOTHY LEE SENSING PHILLIP BUFFINGTON KATHRYN RUSSELL GILCHRIST GLEN AUSTIN STEWART JOHN P. SNEED MARK W. GARRIGA HUGH RUSTON COMLEY TIMOTHY JAMES ANZENBERGER BRANT JAMES RYAN NATURE OF THE CASE: CIVIL - OTHER DISPOSITION: AFFIRMED - 06/20/2024 MOTION FOR REHEARING FILED:

BEFORE KING, P.J., CHAMBERLIN AND ISHEE, JJ.

KING, PRESIDING JUSTICE, FOR THE COURT:

¶1. UnitedHealthcare of Mississippi, Inc. (United), submitted a qualification containing

redacted information to the Mississippi Department of Medicaid (DOM) but ultimately was

not selected for the contract. Subsequently, a public records request was submitted to the

DOM seeking the redacted information contained in United’s qualification. United sought

a protective order exempting the redacted information contained in its qualification from

disclosure. After in camera review, the chancery court found, among other things, that the

governmental sanctions compilation contained in the qualification was not exempt from

disclosure. United appeals and argues that, because the sanctions compilation is either a trade

secret or confidential commercial or financial information, it is protected from disclosure.

Because United failed to meet its burden on either issue, we affirm the decision of the

chancery court.

FACTS AND PROCEDURAL HISTORY

¶2. On December 10, 2021, the DOM issued Request for Qualifications No. 20211210

(the RFQ) seeking Managed Care Organizations (MCOs) to provide Medicaid Managed Care

services after the incumbent contract expired. Mississippi Division of Medicaid, Request for

Qualifications, RFQ # 20211210, https://medicaid.ms.gov/wp-content/uploads/2021/12/

DOM-CCO-Procurement-RFQ-No.-20211210.pdf (last visited June 10, 2024). The RFQ

2 contained a provision stating that, in order to be eligible to submit a qualification, offerors

should provide documentation that the contractor performing the managed care has not been

sanctioned by a state or federal government within the previous ten years. Id. It additionally

contained a provision instructing the offeror to submit a public copy of the qualification from

which any confidential information had been redacted if its qualification had included such

information. Id.

¶3. In response, United, Amerigroup Mississippi, Inc., Magnolia Health Plan, Inc., Molina

Healthcare of Mississippi, and Mississippi True d/b/a TrueCare submitted qualifications.

United included in its qualification a compilation of governmental sanctions that it had

incurred during the relevant time period. The sanctions compilation was redacted in the

public copy that United submitted.

¶4. On August 10, 2022, the DOM awarded contracts to other offerors and not to United.1

Mississippi Division of Medicaid Office of Procurement, Memorandum (Aug. 10, 2022)

http://medicaid.ms.gov/wp-content/uploads/2022/08/CCO-Procurement-Notice-of-Intent-to-

Award-8.10.2022.pdf. Subsequently, United submitted a protest of the DOM’s award

decision. Public Procurement Review Board, Meeting Minutes (Mar. 1, 2023),

https://www.dfa.ms.gov/sites/default/files/PPRB%20Home/Meeting%20Minutes/2023/3

%20PPRB%20Agenda%20%26%20Minutes%203.1.23.pdf.

1 Contracts were awarded to TrueCare, Magnolia, and Molina. Mississippi Division of Medicaid Office of Procurement, Memorandum (Aug. 10, 2022) http://medicaid.ms.gov/wp-content/uploads/2022/08/CCO-Procurement-Notice-of-Intent-to- Award-8.10.2022.pdf.

3 ¶5. On August 23, 2022, United received notice that several public records requests had

been submitted to the DOM regarding the RFQs. Dorsey, Public Procurement Review Board

Rule 1-301 Notice of UnitedHealthcare of Mississippi, Inc. (Sept. 1, 2022),

https://medicaid.ms.gov/wp-content/uploads/2022/09/UHC-PPRB-1-301-Notice-

9.1.22-4896-2110-3153-Final.pdf. Pursuant to Mississippi Code Section 25-61-9:

Records furnished to public bodies by third parties which contain trade secrets or confidential commercial or financial information shall not be subject to inspection, examination, copying or reproduction under this chapter until notice to third parties has been given, but the records shall be released no later than twenty-one (21) days from the date the third parties are given notice by the public body unless the third parties have filed in chancery court a petition seeking a protective order on or before the expiration of the twenty-one-day time period.

Miss. Code Ann. § 25-61-9(1)(a) (Supp. 2023).

¶6. On September 1, 2022, United notified the DOM and other offerors of its intent to

seek a protective order to prevent disclosure of the redacted information contained in its

qualification. On September 12, 2022, United filed a petition for a protective order to prevent

the disclosure of information sought in the public records request, including the sanctions

compilation. United argued that the redacted information sought in the public records request

was either trade secrets or confidential commercial or financial information. Further,

United’s qualification was not selected by eleven out of one thousand possible points;

therefore, United argued that any competitive advantage lost due to the release of its

information could result in significant harm to its business.

¶7. Attached to the petition was the affidavit of Erica Crouch, vice president of proposals

for UnitedHealthcare Community and State. Crouch stated that the RFQ response had

4 contained confidential and proprietary business information, including trade secrets. She

wrote that the MCO market in Mississippi was very competitive and, consequently,

disclosure of the redacted information would cause irreparable and substantial competitive

harm to United.

¶8. TrueCare, Magnolia, Amerigroup, and Molina had also filed petitions for protective

orders, and, because the petitions arose out of the same RFQ process, the chancery court

entered an order consolidating the actions on October 4, 2022. The offerors then submitted

redaction logs, along with their redacted and unredacted proposals, to the chancery court.

¶9. The chancery court conducted an in camera review of the disputed redacted items. On

November 15, 2022, the chancery court entered a protective order that granted United’s

petition in part and denied it in part. The chancery court found, in relevant part, that sanctions

from government authorities are matters of public record subject to disclosure under

applicable state law and ordered the DOM to disclose to the requestors the sanctions

compilation. The court’s order stated that “[t]he disclosed information shall be considered

confidential in nature and may only be used in connection with the MississippiCAN and/or

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UnitedHealthcare of Mississippi, Inc. v. Amerigroup Mississippi, Inc., Magnolia Health Plan, Inc., Molina Healthcare of Mississippi, Inc., Mississippi True d/b/a Truecare and Mississippi Division of Medicaid, Counsel Stack Legal Research, https://law.counselstack.com/opinion/unitedhealthcare-of-mississippi-inc-v-amerigroup-mississippi-inc-miss-2024.