Reid v. BCBSM, Inc., No. 14-2083 (8th Cir. 2015)
Annotate this CaseReid worked as an attorney in Minnesota and received health insurance from Blue Cross through her law firm. In 2008, her son was diagnosed with autism spectrum disorder. One of the treatments he received was behavioral therapy. Reid’s Blue Cross policy initially covered this treatment. In 2012, Blue Cross informed Reid her policy would exclude coverage for behavioral therapy beginning in 2013. Reid sought an injunction. The district court dismissed most of Reid’s claims under FRCP 12(b)(6) but allowed claims under the Minnesota Human Rights Act and the Americans with Disabilities Act. In 2013, Reid moved to Arizona; she lost her BlueCross coverage some time thereafter. Injunctive relief became moot. The district court then entered an order granting Reid’s motion to dismiss, granting Blue Cross’s motion to the extent it sought dismissal, and denying Blue Cross’s motion to the extent it sought vacatur of its earlier Rule 12(b)(6) ruling. The court provided no explanation for its denial of vacatur. The Eighth Circuit remanded to allow the court to provide an explanation.
Court Description: Per Curiam - Before Gruender, Shepherd and Kelly, Circuit Judges] Civil case. In an action seeking to enjoin plaintiff's insurer from excluding certain therapy from coverage, where the district court dismissed certain claims but allowed plaintiff's Minnesota Human Rights Act and ADA claims to proceed, this court has jurisdiction to review the district court's subsequent order granting plaintiff's motion to dismiss the action and denying defendant's motion for vacatur of the ruling permitting the two claims to proceed; the district court did not provide any explanation for its decision to deny vacatur, and the matter is remanded to the district court with directions to provide an explanation for its decision.
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