UnitedHealthcare Insurance Co. v. Maui Memorial Emergency Medical Associates, Inc.
D. Haw. · Updated
Summary
UnitedHealthcare brought a fraud claim against an emergency physician group over its use of the federal IDR process. On July 7, 2026, the District of Hawaii dismissed the case without prejudice and without leave to amend for lack of subject-matter jurisdiction, finding no substantial federal issue in the state-law fraud claim and noting the insurer bypassed the NSA's FAA-based review.
Timeline of rulings
- D. Haw.
Motion to dismiss granted in part; fraud claim does not arise under federal law; action dismissed without prejudice and without leave to amend for lack of subject-matter jurisdiction.
Read the ruling
Why it matters
Like the NorthStar ruling in Pennsylvania, it limits payers' ability to litigate IDR misconduct as state-law fraud in federal court.
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Sources
General information only, not legal advice. Verdict Consulting Group is not a law firm.