Mueller v. Wellmark, Inc.Annotate this Case
In this putative class action, Plaintiffs were doctors of chiropractic who alleged they had been victimized by the discriminatory practices of Iowa's largest health insurer, Wellmark, Inc. The district court (1) granted Wellmark's motion to dismiss claims brought under Iowa's insurance regulatory statutes because no private cause of action was provided therein; (2) granted Wellmark's motion for summary judgment on Plaintiffs' antitrust claims based on the "state action" exemption found in Iowa Code 553.6(4); (3) granted summary judgment on claims alleging Wellmark breached its obligations under a judicially approved national class action settlement in Love v. Blue Cross Blue Shield Ass'n; and (4) granted summary judgment on several specific antitrust claims. The Supreme Court (1) reversed in part, holding that the district court erred in granting summary judgment on Plaintiffs' antitrust claims based on the state action exemption, as the record failed to establish the challenged conduct fell within the exemption; and (2) otherwise affirmed. Remanded.