Louis J. Peterson, D.C. v. UnitedHealth Group Inc., No. 17-1744 (8th Cir. 2019)
Annotate this Case
In these consolidated cases, out-of-network medical providers who United intentionally failed to fully pay for services rendered to United plan beneficiaries in order to offset overpayments to the same providers from other United administered plans filed a class action under the Employee Retirement Income Security Act (ERISA) on behalf of their patients, the plan beneficiaries. Providers claimed that the relevant claim plan documents did not authorize United to engage in cross-plan offsetting.
The Eighth Circuit affirmed the district court's grant of partial summary judgment to providers on the issue of liability and held that nothing in the plan documents even comes close to authorizing cross-plan offsetting. Furthermore, the practice of cross-plan offsetting was in some tension with the requirements of ERISA. While the court need not decide whether cross-plan offsetting necessarily violated ERISA, the court held that United's interpretation of the documents was not reasonable.
Court Description: Grasz, Author, with Shepherd and Melloy, Circuit Judges] Civil case - ERISA. Out-of-network medical providers who United intentionally failed to fully pay for services rendered to United plan beneficiaries in order to offset overpayments to the same providers from other United administered plans, brought this class action, claiming, under ERISA, that the relevant plan documents do not authorize United to engage in cross-plan offsetting; the district court found for the plaintiffs and entered a partial summary judgment for them on the issue of liability. Held, nothing in the plan documents even comes close to authorizing cross-plan offsetting; further, without deciding whether cross-plan offsetting necessarily violates ERISA, United's interpretation of the documents is not reasonable.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.