Guardian Flight, L.L.C. v. Health Care Service Corp.
N.D. Tex. → 5th Cir. → SCOTUS · Updated
Summary
Two air ambulance providers sued HCSC for failing to pay IDR awards on time. The Northern District of Texas dismissed, and on June 12, 2025 the Fifth Circuit affirmed, holding the No Surprises Act has no private right of action and the ERISA and quantum meruit claims were inadequately pleaded. Rehearing en banc was denied, and the Supreme Court denied certiorari on January 12, 2026.
Timeline of rulings
- U.S. Supreme Court
Petition for a writ of certiorari denied (No. 25-441).
Read the ruling - 5th Cir.
Petition for rehearing en banc denied.
- 5th Cir.
Affirmed; the NSA does not contain a private right of action, and providers failed to state derivative ERISA or Texas quantum meruit claims.
Read the ruling - N.D. Tex.
Complaint dismissed.
Why it matters
It is the leading appellate decision against private enforcement of IDR awards, binding in Texas, Louisiana and Mississippi and widely followed by district courts elsewhere. The cert denial left the circuit question open for other courts of appeals.
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Sources
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