MultiPlan, Inc. v. Holland, No. 18-60514 (5th Cir. 2019)
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After plaintiff disputed discounts applied by MultiPlan under his agreement with PHCS to charges for services he provided to patients that were covered by workers' compensation insurance, he filed suit against PHCS and Multiplan. Plaintiff's claims for civil conspiracy and breach of contract proceeded to trial and were subsequently dismissed after the district court granted defendants' motions for judgment as a matter of law.
The Fifth Circuit held that plaintiff failed to show that the district court erred in determining that plaintiff did not establish an underlying "unlawful purpose" or unlawful activity on which to base his civil conspiracy claim. However, the court held that a reasonable jury could find based on the evidence presented that defendants breached the parties' agreement, and thus the district court erred in granting defendants' renewed motion for judgment as a matter of law as to the breach of contract claim. The court upheld the district court's ruling prohibiting additional evidence on punitive damages and the issue of punitive damage from reaching the jury. Finally, the court concluded that the district court's ruling prohibiting Attorney Gordon from participating in trial on plaintiff's behalf did not provide grounds for disturbing any of its judgments. Accordingly, the court affirmed in part, vacated in part, and remanded.
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