A managed care company has taken a step toward beating back a class-action lawsuit.
A 3-judge panel of the 11th U.S. Circuit Court of Appeals has issued a 2-sentence opinion upholding a lower-court ruling in favor of UnitedHealth Group Inc., Minnetonka, Minn., and against the plaintiffs, a class representing doctors who had treated UnitedHealth managed care plan patients.
The courts consolidated the UnitedHealth case with a wave of other managed care suits in Miami under U.S. District Court Judge Federico Moreno. Lawyers for the plaintiffs in the cases accused UnitedHealth and the other managed care companies of conspiring to hold down doctors’ compensation.
The other major defendants in the litigation have negotiated settlements. The settlements call for the companies to pay tens of millions of dollars into settlement funds and to change the way they work with doctors.
But Moreno dismissed all claims in the case against UnitedHealth in June 2006, and the new 11th Circuit ruling has upheld that decision.
“The judgment of the district court is affirmed for the reasons set out in the district court’s order granting summary judgment,” the court writes in the brief opinion explaining its ruling.
The 11th Circuit does not conduct the same analysis of how the “plus factors” provision of antitrust law applies to Racketeering Influenced and Corrupt Organization cases, but “even if that requirement is not applicable, the district court’s judgment is still due to be affirmed under the facts and circumstances of this case,” the court writes.
The 11th Circuit appellate court has jurisdiction over Alabama, Florida and Georgia.
At press time, the defendants were not immediately available to comment, and it was not clear whether the plaintiffs would appeal the 11th Circuit ruling.
If the ruling stands, and UnitedHealth does not negotiate the kind of settlement agreement its competitors have negotiated, the company will not be subject to the kinds of settlement agreement provisions that will regulate many competitors’ dealings with physicians. Typical managed care litigation settlement agreement provisions require that competitors publish detailed contract and pricing information on their physician Web sites.
“We are pleased that this decision puts the Shane vs. Humana class action claims behind us,” Thomas Strickland, UnitedHealth’s chief legal officer, says in a statement about the 11th Circuit ruling. “This ruling affirms the Southern District Court of Florida’s finding in support of our position that there was no evidence of improper conduct by UnitedHealth Group.”
The company “looks forward to continuing to work collegially with physicians and their professional organizations to improve the quality of care delivery and to simplify health care administration,” Strickland says.